# Response to Public Comments on Greenhouse Gas Reporting Rule:
2014 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems

`November 2014



## Response to Public Comments on the Greenhouse Gas Reporting Rule: 2014 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems

U. S. Environmental Protection Agency Office of Atmospheric Programs Climate Change Division Washington, D.C.

`

### FOREWORD This document provides EPA’s responses to public comments on the Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems. The EPA published a Notice of Proposed Rulemaking in the Federal Register on March 10, 2014 (79 FR 13394). The proposed amendments we re designed to correct ambiguities or minor inconsistencies in greenhouse gas monitoring, calculation, and reporting requirements; amend monitoring and quality assurance meth ods to provide flexibility for certain facilities; clarify certain terms and definitions, and make other corrections identified as a result of working with the affected sources during rule implementation and outreach. In conjunction with this action, we pr oposed confidentiality determinations for the new and substantially revised (i.e., requiring additional or different data to be reported) data elements contained in these amendments and proposed to revise the confidentiality determination for one existing data element. During the 45

- day public comment period, EPA received comment letters from industry representatives and associations, environmental organizations, and private citizens in response to the March 10 , 201 4 proposal. This document provides EPA’s responses to the significant public comments regarding these proposals. The verbatim text of each comment extracted from the original comment letters is included in this document, arranged by subject. For each commen t, the name and affiliation of the commenter, the document control number (DCN) assigned to the comment letter, and the number of the comment excerpt are provided. W here possible, EPA separated comments on specific topics into their respective data categor ies. However, in some cases, commenters made broad statements about the proposed amendments to subpart W or general comments on the approach that could not be easily separated by topic or data category without potentially affecting the intended meaning of the commenter’s statements. In such cases, we either repeated the comment excerpt in its entirety in each of the relevant sections of this document or referred the reader to the response to another similar comment

. EPA’s responses to comments are generall y provided immediately following each comment excerpt. In some cases, EPA provided responses to specific comments or groups of similar comments in the preamble to the final rulemaking. Rather than repeating those responses in this document, EPA has referen ced the preamble to the final rule. In some cases, a commenter incorporated by reference the comments of another company or organization. Rather than repeat these comment excerpts for each commenter, EPA has listed the comment excerpt only once under the n ame of the person, company or organization who submitted the comment and includ ed a list of commenters who indicated their support for that comment in a footnote. Copies of all comment letters submitted are available at the EPA Docket Center Public Reading Room or electronically through http://www.regulations.gov by searching Docket Id. No. EPA

- HQ

OAR

- 201 1

- 0 512

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iiiThe primary contact regarding questions or comments on this document is:
Carole Cook (202) 343

- 9263 U.S. Environmental Protection Agency Office of Atmospheric Programs Climate Change Division Mail Code 6207

- A 1200 Pennsylvania Avenue, NW Washington, D.C. 20460
For technical information, contact the Greenhouse Gas Reporting Rule Hotline at: http://www.epa.gov/ghgreporting/contactus.html

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ivTABLE OF CONTENTS Page



### FOREWORD
................................ ................................ ................................ .................... iii List of Commenters
................................ ................................ ................................ .......... ix Acronyms and Abbreviations
................................ ................................ ........................... x 1. 0 General Comments
................................ ................................ ................................ . 1 2.0 Revisions to Provide Consistency Throughout Subpart W
................................ 5 2.1 Revisions for the consistency of the units of measure for reporting

............................. 5 2.2 Definition of onshore petroleum and natural gas production

................................ ........ 5 2.3 Definition of sub

- basin category

................................ ................................ ................... 8 

### 3.0 Natural Gas Pneumatic Device Venting
................................ ............................... 9 3.1 Use of site

- specific gas composition data for natural pneumatic devices in revisions to Eqn. W

- 1

................................ ................................ ................................ ................. 9 3.2 Comments on other minor revisions and restructuring of reporting requirements for natural gas pneumatic device venting

................................ ................................ ........ 10 

### 4.0 Acid Gas Removal Vents
................................ ................................ ...................... 10 5.0 Dehydrators
................................ ................................ ................................ ........... 12 5.1 Minor Revisions to Calculation Methods (e.g., accounting for venting to vapor recovery or flare)

................................ ................................ ................................ ....... 12 5.2 Comments on other minor revisions and restructuring of reporting requirements for dehydrators

................................ ................................ ................................ ................ 15 

### 6.0 Well Venting for Liquids Unloading
................................ ................................ .. 18 6.1 Revisions to Calculation Method 1 to allow for annualizing venting data (Equations W

- 7A and W

- 7B)

................................ ................................ ................................ ...... 18 6.2 Revisions to Calcula tion Method 1 and 2 to separate calculation of emissions from wells with plunger lifts and wells without plunger lifts

................................ ............ 21 6.3 Revi sions to term "SPp"ed (well shut

- in pressure or surface pressure) of Equation W

8

................................ ................................ ................................ ................................ . 22 6.4 Comments on other minor revisions and re structuring of reporting requirements for well venting for liquids unloading

................................ ................................ ............. 22

v

### Table of Contents (Continued) Page 

### 7.0 Gas Well Completions and Workovers with Hydraulic Fracturing
................ 24 7.1 Comments on proposed definitions for "reduced emissions completion," "reduced emissions workover," and "well completions"

................................ .......................... 24 7.2 Revisions to Equations W

- 10A and W

- 10B

................................ ................................ 27 7.3 Clarifications to §98.233(g)(1) and (g)(2)

................................ ................................ ... 29 7.4 Comments on other minor revisions and restructuring of reporting requirements for gas well completions and workovers with hydraulic fracturing

................................ 32 

### 8.0 Gas Well Completions and Workovers Without Hydraulic Fracturing
......... 36 9.0 Blowdown Vents
................................ ................................ ................................ ... 37 9.1 Revisions to Equations W

- 14A and W

- 14B to add a compressibility term (includes harmonizing changes to Equations W

- 33 and W

- 34)

................................ ................ 37 9.2 Revisions to require reporting of aggregated blowdown emissions (in lieu of by "unique physical volume")

................................ ................................ ........................ 50 9.3 Optional calculation method where a flow meter is in use on a blow down vent

- proposed §98.233(i)(3)

................................ ................................ .............................. 55 9.4 Comments on other minor revisions and restructuring of reporting requirements for blowdown vents

................................ ................................ ................................ ......... 56 

### 10.0 Onshore Production Storage Tanks
................................ ................................ ... 56 11.0 Transmission Storage Tanks
................................ ................................ ............... 58 11.1 Revisions to methods for quantifying emissions from the tank vapor vent stack

..... 58 11.2 Comments on other minor revisions a nd restructuring of reporting requirements for onshore transmission condensate storage tanks

................................ ........................ 59 

### 12.0 Well Testing Venting and Flaring
................................ ................................ ....... 60 13.0 Associated Gas Venting and Flaring
................................ ................................ .. 61 14.0 Flare Stack Emissions
................................ ................................ .......................... 63 15.0 Centrifugal and Reciprocating Compressors
................................ .................... 65 15.1 Comments on proposed requirements for conducting volumetric emissions measurements for centrifugal or reciprocating compressors vented to common manifold or flare

................................ ................................ ................................ ........ 65 15.2 Proposed definitions for "compressor mode", compressor source", "manifolded compressor source", and "manifolded group of compressor sources"

...................... 76 15.3 Revisions to calculation and reporting of emissions for compressors routed to a flare 79 15.4 Revisions to 3

- year cycle requirement, schedule to measure compressors in the not

operating

- depressurized mode, & schedule to measure compressors in the operating mode

................................ ................................ ................................ .......................... 80

vi

### Table of Contents (Continued) Page 15.5 Use of as found leak measurements to develop reporter emission factors in Equations W

- 23 and W

- 28.

................................ ................................ ....................... 96 15.6 Comments on other minor revisions and restructuring of reporting requirements for centrifugal and reciprocating compressors

................................ ................................ 99 15.7 Comments on emission factor approach for compressors

................................ ....... 128 15.8 Other comments on issues not proposed related to centrifugal and reciprocating compressors
................................ ................................ ................................ ............. 135 

### 16.0 Leak Detection Equipment and Emissions from Components
...................... 145 16.1 Revisions to §98.233(q) and (r) and calculation of facility meter/regulator run emission factor

................................ ................................ ................................ ......... 145 16.2 Calculation of emissions from above grade transmission

- distribution (T

- D) transfer stations.

................................ ................................ ................................ .................... 145 16.3 Calculation of em issions from below grade Emissions from below grade metering regulating stations, below grade transmission

- distribution transfer stations, distribution mains, and distribution services.

................................ .......................... 149 16.4 Comments on applicable definitions and other minor revisions and restructuring of reporting requirements for leak detection and emissions from components.

.......... 150 

### 17.0 Calculation of GHG Emissions from Natural Gas Volume Emissions
......... 1 55 17.1 Comments on the use of default or site

- specific gas composition

.......................... 155 17.2 Comments on the need to use “actual” versus “standard” conditions

..................... 159 

### 18.0 Onshore Petroleum and Natural Gas Production and Natural Gas Distribution Combustion Sources
................................ ................................ ..... 161 19.0 Revisions to Missing Data Provisions
................................ ............................... 162 19.1 Revisions to §98.235 to specify the use, treatment, and reporting of missing data 162 19.2 Provisions for newly acquired wells or sources

................................ .................. 183 

### 20.0 Best Available Monitoring Methods
................................ ................................ . 186 20.1 Removal of BAMM requirements for 2015 and beyond

................................ ......... 186 20.2 Requests for transitional BAMM for 2015

................................ .............................. 198 20.3 Dehydrators

................................ ................................ ................................ ............. 202 

### 21.0 General Revisions to Reporting Requirements (including addition of new reporting elements)
................................ ................................ ............................. 208 22.0 Confidentiality Determinations and Data Category Assignments for New or Revised Data Elements
................................ ................................ ....................... 218 22.1 EPA’s Approach to confidentiality determinations and data category assignments for new or revised data elements

................................ ................................ ............. 218

vii

### Table of Contents (Continued) Page 22.2 Comments on proposed confidentiality determinations for data elements that are not inputs to emission equations

................................ ................................ .................... 219 22.3 Comments on evaluation of inputs to emissions equations for new or revised data elements

................................ ................................ ................................ ................... 233 22.4 Concerns related to exploratory wells

................................ ................................ ..... 236 

### 23.0 Impacts of the Proposed Amendments
................................ ............................. 252 24.0 Out of Scope Comments: General Comments Outside of the Scope of the Amendments
................................ ................................ ................................ ....... 262

viii

### List of Commenters D ocument C ontrol N umber Commenter Name Commenter Affiliation EPA

- HQ

- OAR

- 2011

- 0512

- 0069 Kathleen McNeil None EPA

- HQ

- OAR

- 2011

- 0512

- 0070 D. E. Ortman None EPA

- HQ

- OAR

- 2011

- 0512

- 0071 Anonymous Commenter None
EPA

- HQ

- OAR

- 2011

- 0512

- 0072 Gary W. Smith None EPA

- HQ

- OAR

- 2011

- 0512

- 0073

- A1 Pamela Faggert Dominion Resources Services, Inc. EPA

- HQ

- OAR

- 2011

- 0512

- 0074

- A1 Bert Kalisch American Public Gas Association EPA

- HQ

- OAR

- 2011

- 0512

- 0075 Charlotte Lewis None EPA

- HQ

- OAR

- 2011

- 0512

- 0076

- A1 Kelly Guertin DTE Energy EPA

- HQ

- OAR

- 2011

- 0512

- 0077

- A1 Thomas J. Bach Kinder Morgan Energy Partners, L.P EPA

- HQ

- OAR

- 2011

- 0512

- 0078

- A1 Thure Cannon Texas Pipeline Association (TPA) 1 EPA

- HQ

- OAR

- 2011

- 0512

- 0079

- A1 Ritu Talwar Spectra Energy Corp EPA

- HQ

- OAR

- 2011

- 0512

- 0080

- A1 Carrie B. Crumpton CONSOL Energy, Inc. EPA

- HQ

- OAR

- 2011

- 0512

- 0081

- A1 through

- A6 Lisa Beal I nterstate N atural G as A ssociation of A merica (INGAA) 1 EPA

- HQ

- OAR

- 2011

- 0512

- 0082

- A1 Eldon Lindt Xcel Energy, Inc. 2 EPA

- HQ

- OAR

- 2011

- 0512

- 0083

- A1 Pamela Lacey A merican G as A ssociation (AGA) 2 EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Karin Ritter American Petroleum Institute (API) 3 EPA

- HQ

- OAR

- 2011

- 0512

- 0085

- A2 V. Bruce Thompson American Exploration & Production Council (AXPC) 4 EPA

- HQ

- OAR

- 2011

- 0512

- 0086

- A2 Darrell R. Johnson Southern California Gas Compan y (SoCal Gas) 1 EPA

- HQ

- OAR

- 2011

- 0512

- 0087

- A2 Brian Korpics Environmental Defense Fund 5 EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A2 and

- A3 Jeff Applekamp Gas Processors Association (GPA) 1 , 3 EPA

- HQ

- OAR

- 2011

- 0512

- 0091

- A2 Glen Jasek Williams Partners, LP

1 The comments by INGAA were also supported by the Texas Pipeline Association (Docket Id. No. EPA

- HQ

- OAR

2011

- 0512

- 0078

- A1) , Southern California Gas Company (Docket Id. No. EPA

- HQ

- OAR

- 2011

- 0512

- 0086

- A2), and Gas Processors Association (Docket Id. No. EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A2).

2 The comments by American Gas Association (AGA) were also supported by Xcel Energy, Inc. (Docket Id. No. EPA

- HQ

- OAR

- 2011

- 0512

- 0082

- A1 ).

3 Th e comments by American Petroleum Institute (API) were also supported by the Gas Processors Association (Docket Id. No. EPA

- HQ

- OAR

- 2012

- 0934

- 0089

- A2)

. 4 The comments submitted by V. Bruce Thompson of the American Exploration & Production Council (AXPC) represent the comments from AXPC and the Western Energy Alliance. 5 The comments submitted by Brian Korpics of the Environmental Defense Fund represent the comments from Environmental Defense Fund, Clean Air Task Force, Earthjustice, Natural Resources Defense Council, and Sierra Club.

ix

### Acronyms and Abbreviations

AGA American Gas Association API American Petroleum Institute ARP Acid Rain Program AXPC American Exploration & Production Council BAMM best available monitoring methods bbl barrels CAA Clean Air Act CBI confidential business information CFR Code of Federal Regulations CH 4 methane CO 2 carbon dioxide CO 2 e carbon dioxide equivalent DR designated representative EPA U.S. Environmental Protection Agency FERC Federal Energy Regulatory Commission FR Federal Register GHG greenhouse gas GHGRP Greenhouse Gas Reporting Program GHGRR Greenhouse Gas Reporting Rule GOR gas to oil ratio GPA Gas Processors Association GWP global warming potential INGAA Interstate Natural Gas Association of America IR infrared LNG li quefied natural gas mmBtu million British thermal units MMscf million standard cubic feet N 2 O nitrous oxide NAICS North American Industry Classification System NESHAP National Emission Standards for Hazardous Air Pollutants NGL natural gas liquids NOD not

- operating

- depressurized

xNSPS New Source Performance Standards NSR New Source Review NTTAA National Technology Transfer and Advancement Act OMB Office of Management and Budget psig pound per square inch gauge QA/QC quality assurance/quality control REC reduced emissions completion RFA Regulatory Flexibility Act scf standard cubic feet SoCal Gas Southern California Gas Company T

- D transmission

- distribution T&S transmission and storage TPA Texas Pipeline Association TSD Technical Support Document U.S. Unit ed States

xi

### 1.0 General Comments

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0081

- A1 Comment Excerpt Number: 3
Comment: Starting with the 2009 proposed rule, there have been ten Subpart W rulemakings in less than five years. This does not include other GHGRP amendments related to the Subpart A general provisions and Subpart C combustion equipment that also affect Subpart W facilities. The sheer number of rulemakings is unprecedented in our experience with numerous air quality regulations over several decades. In previous Subpart W comments, INGAA recommended a delayed or staged implementation approach to address the challeng es evident in earlier versions of the rule. The iterative rulemaking process needed to support the initial years of Subpart W implementation appear to confirm the validity of INGAA’s request. To support Subpart W improvement, INGAA has expended extraordina ry effort over the last five years. In addition to the commenting on multiple rulemakings, EPA has provided additional material to EPA. For example, in 2011 INGAA provided a quick response to EPA requests to recommend Subpart W revisions related to errors and lack of clarity in the compressor emission sections. Unfortunately, EPA failed to respond to this requested material in the two late 2011 rulemakings, and the material was re

- submitted in subsequent INGAA comments 4

. Despite these challenges, INGAA rema ins committed to providing constructive comments and working with EPA to improve Subpart W. Although there have been numerous Subpart W rulemakings, the Proposed Rule is the first substantive revision of compressor

- related emission estimation issues since the 2010 re

- proposal. Several issues remain that have been longstanding concerns. INGAA comments in response to primary Subpart W rulemakings are referenced within these comments and provided as attachments , including:

• Docket document number EPA

- HQ

- OAR

- 200 8

- 0508

- 0480.1; INGAA June 9, 2009 comments in response to April 10, 2009 GHGRP Proposed Rule (Attachment 1);

• Docket document number EPA

- HQ

- OAR

- 2009

- 0923

- 1039; INGAA June 11, 2010 comments in response to the April 12, 2010 Proposed Subpart W Rule which sign ificantly revised the original 2009 Subpart W proposal (Attachment 2);

• Docket document number EPA

- HQ

- OAR

- 2011

- 0147

- 0029; INGAA September 19, 2011 comments in response to August 4, 2011 Proposed Subpart W Amendments (Attachment 3);

• Docket document number EP A

- HQ

- OAR

- 2011

- 0512

- 0029; INGAA October 24, 2011 comments in response to September 9, 2011 Proposed Subpart W Amendments (Attachment 4);

1• Docket document number EPA

- HQ

- OAR

- 2011

- 0147

- 0047; INGAA June 20, 2012 comments in response to May 21, 2012 Proposed Subp art W Amendments (Attachment 5). Footnotes:

4 "INGAA Comments Regarding the Proposed Rule, Mandatory Reporting of Greenhouse Gases, dated September 9, 2011; Attachment 2," EPA

- HQ

- OAR

- 2011

- 0512

- 0029 (October 24, 2011). Response: The EPA appreciates the com menter's concern regarding the ongoing development of the subpart W requirements for calculating and reporting GHG emissions. During th e development of subpart W, the EPA has proposed and finalized rulemakings that establish and improve the reporting metho d s of this subpart. The 2014 proposed rule amendments (79 F R 13394, March 10, 2014), further improve reporting methods for subpart W and address many of issues identified by the commenter and other stakeholders. However, the EPA is not addressing comments on prior Subpart W rulemakings in this final rule, as these comments are beyond the scope of the revisions and clarifications included in this rulemaking. The EPA appreciates the commenter's continued commitment to subpart W. The EPA has considered and, where appropriate, revised the proposed rule to address the comments on the proposed amendments and the additional data provided during the public comment period, as discussed in this document and in the preamble t o the final rule

.

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0073

- A1 Comment Excerpt Number: 1
Comment: We appreciate EPA's response to concerns regarding ca lculation methodologies and definitions. EPA has made several changes that will assist reporters in providing consistent and accurate data by making clarifying and simplifying changes to calculations and inputs without significantly increasing the reportin g burden. Several proposed changes will clarify or simplify calculations and provide consistency throughout the rule by more closely aligning the calculation methods with the reporting requirements, more clearly identifying emission sources, and allowing s ources alternative ways to address missing data. Response: The EPA thanks the commenter for their support. The EPA has considered and, where appropriate, revised the proposed rule to address the comments on the proposed amendments and the additional data provided during the public comment period, as discussed in this document and in the preamble to the final rule

.

Commenter Name: Charlotte Lewis Commenter Affiliation: Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0075 Comment Excerpt Number: 1

2Comme nt: I believe this proposed rule is of utmost importance given the need for more data concerning the quantity of methane emissions during the lifetime of a well. Methane (CH4) is a more potent greenhouse gas than carbon dioxide (CO2), though it has a shor ter life span (12.4 years) than CO2 (100 years) in the atmosphere. The Contribution of Working Group 1 to the Fifth Report of the Intergovernmental Panel on Climate Change indicates that the global warming potential (GWP) of CH4 is 86 in a 20

- year span and 34 in a span of 100 years. NASA Goddard Institute of Space Studies scientists Drew T. Shindell, Greg Faluvegi, Dorothy M. Koch, Gavin A. Schmidt, Nadine Unger, and Susanne E. Bauer in "Improved Attribution to Climate Forcing to Emissions", an article in t he American Association for the Advancement of Science online magazine in 2009, the GWP of CH4 in a 20

- year span is 105, and in 100 years, 33. According to James Hansen, Makiko Sato, Pushker Kharecha, Gary Russell, David W Lea, and Mark Siddal (“Climate ch ange and trace gases.” Philosophical Transactions of the Royal Society (2007): 1925

- 1928. Web.), CH4 is responsible for 40% more positive radiative forcing in the atmosphere due to causing tropospheric ozone (O3) emissions in the troposphere and water vapo r in the stratosphere. To keep methane emissions and other short

- lived greenhouse gas emissions from throwing humanity beyond the 2 degree Celsius tipping point established by the 16th Session of the Parties to the U.N. Framework on Climate Change, there n eeds to be transparency concerning how much of these emissions are being released into the atmosphere. The confidentially determinations and removal of the “ Best Available Monitoring Methods ” with refined measurement methodology as proposed in the rule, wi ll sufficiently do so. And based on what research has been done, particularly by The National Oceanic and Atmospheric Administration and the University of Colorado, the levels of methane from natural gas production are offsetting its lesser CO2 emissions d uring burning, and derailing climate change mitigation. According to the Energy Information Administration's “ Annual Energy Outlook 2013 ”, shale

- gas production is projected to grow 113% by 2040. In any swiftly growing industry, scientific research and legi slative protection of performing research, should be at the forefront to ensure the safety of human and other species' communities. This rule proposal is essential to the United States, the world's second highest producer of greenhouse gases (according to the Energy Information Administration). If we are to meet the Intergovernmental Panel on Climate Change's emission targets, data on methane emissions must be transparent. The consequences from this potent greenhouse gas are enormous, on a world

- wide scale if left unchecked. Please pass the Environmental Protection Agency Proposed Rule: Greenhouse Gas Reporting: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems. Response: The EPA thanks the commenter for their support. The EPA has considered and, where appropriate, revised the proposed rule to address the comments on the proposed amendments and the additional data provided during the public comment period, as discussed in this document and in the preamble to the final rule

. Commenter Name: Gary W. Smith Commenter Affiliation: Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0072 Comment Excerpt Number: 1

3Comment: It is neither rational, reasonable nor prudent that the level of intrusive reporting contained in the proposed update to 40 CFR Part 98 be imposed on an already over

- burdened industry that is effectively the only engine of economic success currently operating within the United States. By its very nature, the detail imposed by this change will add operating expense to provide the data on gasses, the very nature of which is not scientifically established as detrimental to the nation nor the world, in fact, the opposite by their very nature. I urge you to suspend this update and reconsider the negative impact of the en tire concept that has been implemented by such regulatory acts. Response: The EPA thanks the commenter for their input and appreciates the commenter's concern over the complexity and burden of the subpart W requirements for calculating and reporting GHG emissions. However, the overall approach of estimating and reporting GHG emissions for subpart W is driven in part by the go al of providing flexibility to accommodate the needs of a number of different reporters. The 2014 proposed rule amendments (79 FR 13394, March 10, 2014), further improve reporting methods for subpart W and address many of issues identified by various stake holders. In many cases, the revisions that are being made reduce the burden on those facilities required to report GHG emissions. The EPA has considered and, where appropriate, revised the proposed rule to address the comments on the proposed amendments an d the additional data provided during the public comment period, as discussed in this document and in the preamble to the final rule.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- H Q

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 21
Comment: For the reasons API describes herein, and in its November 29, 2013 comments, if unchanged, the issues API raised will result in requirements that are overly burdensome, harmful to industry, infe asible to implement, and constitute arbitrary and capricious decision making. While API supports the bulk of EPA’s proposed revisions, we respectfully request that EPA address the specific issues outlined here, in the final rule, to avoid arbitrary and cap ricious action. Response: The EPA appreciates the concerns expressed by the commenter as well as their support for many on the proposed rule revisions. We strongly disagree with the commenter that the final rule constitutes arbitrary and capricious decisi on making. The EPA has considered and, where appropriate, revised the proposed rule to address the comments on the proposed amendments and the additional data provided during the public comment period, as discussed in this document and in the preamble to t he final rule

.

4

### 2.0 Revisions to Provide Consistency Throughout Subpart W
2.1 Revisions for the consistency of the units of measure for reporting

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EP A

- HQ

- OAR

- 2011

- 0512

- 0073

- A1 Comment Excerpt Number: 2
Comment: Changes in the units of measure for emissions reporting will lead to less confusion and easier inter

- comparisons with other sectors, without introducing inconsistent convers ion calculation met hodologies. EPA is proposing to require reporting in units of metric tons of methane, carbon dioxide, and nitrous oxide instead of the current units of their carbon dioxide equivalent (CO2e) of these constituents. This proposed change is intended to increa se consistency between the reporting requirements for Subpart W and the rest of the Mandatory Reporting Rule which generally require reporting in terms of the individual GHGs rather than their CO2e. We support this proposed change. Response: The EPA thank s the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0091

- A2 Comment Excerpt Number: 1
Comment: Proposed EPA Amendment: Revise the reporting of GHG emissions in Subpart W from metric tons of CO2e of each reported GHG to metric tons of the individual GHG. Williams supports the proposed amendment, as it aligns Subpart W with other subparts of Part 98 with respe ct to GHG reporting. It also affects a more meaningful comparison of GHG emissions between reporting years where global warming potentials are different. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed. 

### 2.2 Definition of onshore petroleum and natural gas production

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0073

- A1 Comment Excerpt Number: 3

5Comment: Several definit ions are proposed to be changed or added to provide needed clarity to the rule. The changes in definitions will clarify and provide consistency going forward in our understanding of these terms. The definition of “ onshore petroleum and natural gas producti on ” is proposed to be changed to clarify the equipment types that are covered by the rule. We support these changes that provide needed clarity. Response: The EPA thanks the commenter for their support. The EPA is finalizing the definition of “ onshore pet roleum and natural production ” with minor revisions. See Section II.A.2 of the preamble to the final rule for additional information.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 4
Comment: Onshore Production Source Category : API supports EPA’s proposal to revise the source category definition of onshore petroleum and natural gas production found at 40 C.F.R. 98.230(a)(2) to im prove the clarity of the emission sources in onshore petroleum and natural gas production to which the reporting requirements apply. Specifically, API supports the removal of non
- transportation related equipment from the source category definition. Response: The EPA thanks the commenter for their support. The EPA is finalizing the definition of “ onshore petroleum and natural production ” with minor revisions. See Section II.A.2 of the preamble to the final rule for additional information.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 43
Comment: Revisions to §98.230: EPA is proposing to revise the definition of the onshore petr oleum and natural gas production source category. API supports the removal of “auxiliary non

- transportation related equipment”, which API requested in comments on the September 9, 2011 pro posed amendments to Subpart W. However, the revisions to the langua ge include the addition of “maintenance and repair equipment” in the list of portable non

- self propelled equipment. Based on the current rule language, maintenance and repair equipment is not included in the onshore production industry segment because this equipment is not directly used in the production, extraction, recovery, lifting, stabilization, separation, or treating of petroleum and natural gas. This is supported by the description of stationary and portable fuel combustion equipment at 40 CFR 98.23 2(c)(22) as follows:

6Stationary or portable equipment are the following equipment, which are integral to the extraction, processing, or movement of oil or natural gas: well drilling and completion equipment, workover equipment, natural gas dehydrators, nat ural gas compressors, electrical generators, steam boilers, and process heaters. Also, tracking and reporting emissions from combustion equipment used for maintenance and repair purposes, such as welding machines and pressure washers, would be burdensome i n terms of time and effort required to maintain logs of this equipment, and provide little benefit due to the relatively small emissions from these sources in comparison to the equipment that is integral to the drilling and production operation, such as th e prime movers. Therefore, EPA should remove the reference to maintenance and repair equipment in the definition of onshore petroleum and natural gas production. As an example of the small contribution these units make to overall emissions, emissions from maintenance equipment were tracked for one onshore well site during RY2012. This well site performed drilling activities during the entire reporting year. Over the year, the well site tracked engine runtimes on 170 pieces of equipment that came on the wel l pad. There were 16 pieces of equipment that would be considered “maintenance and repair,” including welding machines, pressure washers, and stormwater pumps, representing 9% of the total combustion equipment tracked. These 16 maintenance and repair engin es were small in terms of HP rating, the largest of which had a HP rating of 41 and the average size of 22 hp. Additionally, the average time spent onsite was only 16 days out of the year with an average runtime of 53 hours. Total GHG emissions from these units equaled 10.7 tonnes CO2e, in comparison to the total emissions of 8974.4 tonnes CO2e that this well site contributed to the basin. Consequently, tracking these 16 additional engines over the very brief time periods they were onsite only increased emi ssions by 0.12%. API urges EPA to remove the addition of “maintenance and repair equipment” from the list of portable non

- self propelled equipment as this equipment is not use in the production, extraction, recovery, lifting, stabilization, separation, or treating of petroleum and natural gas. This equipment is frequently moved between well sites, such that even tracking the count of this equipment is extremely burdensome with no relative benefit to improving emissions estimation. Response: The EPA is remo ving the reference to “maintenance and repair equipment” from the source category definition for the onshore petroleum and natural gas production segment in this final rule. See Section II.A.2 of the preamble to the final rule for additional discussion res ponding to this comment.

Commenter Name: V. Bruce Thompson Commenter Affiliation: American Exploration & Production Council (AXPC) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0085

- A2 Comment Excerpt Number: 9
Comment: AXPC and the Alliance request that EPA reconsider the inclusion of maintenance and repair equipment in the portable combustion source category. As has been clearly stated in

7the rule since initially promulgated, the portable emissions are required to be reported are limited to those t hat are involved in the extraction of hydrocarbons. The extension of this source category, which is already one of the most challenging reporting categories in terms of third party data collection efforts, is unjustified and in conflict with what EPA initi ally intended to be reported. As such we request that EPA remove “maintenance and repair equipment” from the §98.230(2) definition of the onshore production sector. Response: The EPA is removing the reference to “maintenance and repair equipment” from the source category definition for the onshore petroleum and natural gas production segment in this final rule. See Section II.A.2 of the preamble to the final rule for additional discussion responding to this comment. 

### 2.3 Definition of sub
- basin category

Comment er Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 42
Comment: (§98.230) Revised definition for Sub
- basin category : Sub

- basin category, for onsh ore natural gas production, means a subdivision of a basin into the unique combination of wells with the surface coordinates within the boundaries of an individual county and subsurface completion in one or more of each of the following five formation type s: Oil, high permeability gas, shale gas, coal seam, or other tight gas reservoir rock. The distinction between high permeability gas and tight gas reservoirs shall be designated as follows: High permeability gas reservoirs with >0.1 millidarcy permeabilit y, and tight gas reservoirs with ≤0.1 millidarcy permeability. Permeability for a reservoir type shall be determined by engineering estimate. Wells that produce only from high permeability gas, shale gas, coal seam, or other tight gas reservoir rock are co nsidered gas wells; gas wells producing from more than one of these formation types shall be classified into only one type based on the formation with the most contribution to production as determined by engineering knowledge. All wells that produce hydroc arbon liquids (with or without gas) and do not meet the definition of a gas well in this sub

basin category definition are considered to be in the oil formation. All emission sources that handle condensate from gas wells in high permeability gas, shale gas , or tight gas reservoir rock formations are considered to be in the formation that the gas well belongs to and not in the oil formation. API supports these revisions. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

8

### 3.0 Natural Gas Pneumatic Device Venting
3.1 Use of site
- spec ific gas composition data for natural pneumatic devices in revisions to Eqn. W
- 1

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0091

- A2 Comment Excerpt Number: 4
Comment: Proposed EPA Amendment: For natural gas pneumatic devices in the onshore natural gas transmission, compression, and underground storage segment, allow the use of either site

- specific data on gas composition, or the default gas composition (95 percent CH 4 and 1 percent CO 2 ). Williams supports the proposed amendment because it allows reporters the option of using site

specific (versus mandatory default) gas composition data. Response: The EPA thanks the commenter for their support. The EPA is finalizing revisions to allow natural gas transmission compression and underground natural gas storage facilities the option to use either site

- specific composit ion data or to use a default gas composition to calculate emissions from continuous high bleed, continuous low bleed, and intermittent bleed natural gas pneumatic devices. See Section s II.B.1 and II.B.13 of the preamble to the final rule for additional discussion responding to this comment.

Commen ter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0073

- A1 Comment Excerpt Number: 8
Comment: Natural Gas Pneumatic Device Venting. The calculation method used for natural ga s pneumatic device venting is proposed to be changed to expand the use of site

- specific data for gas composition, if available. This proposal is similar to the one discussed above, but is specific to the determination of pneumatic device venting. Currently , a default gas composition of 95% methane and 1 % carbon dioxide is used in the calculations. This change would allow for a more accurate emissions estimate, if site

- specific information is available; however, the current default provides a conservative es timate and the additional cost of conducting gas analysis where data is not available is not justified. EPA has specifically requesting comment on whether or not the use of site

- specific gas composition data for calculating emissions should be mandatory or optional and requests specific details on when a facility would not have site

- specific data available. Gas composition information is maintained by most natural gas companies only to the extent needed to document compliance with the specifications in the FERC tariff. Most companies, including ours, do not maintain site

- specific gas compositions at each station and the logistics and cost of conducting additional gas analysis will increase the program costs. We

9request the agency not make the use of site

- spe cific gas composition mandatory because the default value of 95% methane and 1 % carbon dioxide is conservative in that most gas compositions that are significantly different than the default would have a lower CO 2 e than that of the default composition. We request that the rule allow the option of using site

- specific gas composition if it is available and, if not, to continue to use the default composition. Response: The EPA is finalizing revisions to allow natural gas transmission compression and undergrou nd natural gas storage facilities the option to use either site

- specific composition data or to use a default gas composition to calculate emissions from continuous high bleed, continuous low bleed, and intermittent bleed natural gas pneumatic devices. See Section II.B.1 and II.B.13 of the preamble to the final rule for additional discussion responding to this comment. 

### 3.2 Comments on other minor revisions and restructuring of reporting requirements for natural gas pneumatic device venting

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A3 Comment Excerpt Number: 30
Comment: Pneumatic device reporting: In 98.236(b), it appears that EPA is removing the requirement to report information separately for each pneumatic controllers type (continuous high bleed, continuous low bleed, intermittent bleed), and is instead requesting that all information from all three categories be lumped together. This seems like a backwards step in data collection and, given the current high interest in pneumatic controllers in oil and gas sector studies and by the EPA in NSPS OOOO White Papers, it seem s illogical for EPA to stop collecting this device

- type

- specific information. It appears that EPA may be unsure if the data is being collected as a total or per device type as the proposed rule text at 98.236(b) says, “ you must report the information speci fied in paragraphs (b)(1) through (b)(4) of this section ” while the memorandum entitled “ Revisions to the Subpart W Reporting Requirements as proposed in the Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natu ral Gas Systems; Proposed Rule ” says, “ you must report the information specified in paragraphs (b)(1) through (b)(4) of this section for each device type .” (emphasis added). Response: The EPA agrees with the commenter. It was not our intent to collect agg regated data for each type of pneumatic controller and the proposed ru le text is incorrect. As such, the EPA has revised § 98.236(b) in the final rule to clarify that the data must be reported for each device type.



### 4.0 A cid G as R emoval V ents

Commenter Name: K arin Ritter Commenter Affiliation: American Petroleum Institute (API)

10Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 93
Comment: Acid gas removal (AGR) vents Revisions to §98.233(d)(10): EPA proposes to revise paragraph (10) as indicated: (10) Calculate annual mass CO 2 emissions at standard conditions Mass CO2 emissions shall be calculated from volumetric CO 2 emissions using calculations in paragraph (v) of this section.
The reference to standard conditions is not relevan t for mass emissions. EPA has in fact corrected previous rule language similar to this proposed change (refer to Federal Register / Vol. 76, No. 247 / Friday, December 23, 2011: Mandatory Reporting of Greenhouse Gases: Technical Revisions to the Petroleum and Natural Gas Systems Category of the Greenhouse Gas Reporting Rule

– Final Rule, page 80559, modifications to Equation W

- 1). The proposed text revisions to this paragraph are not necessary and should not be included in the final rule. Response: The EPA agrees with the commenter that the reference to standard conditions is not relevant for mass emissions. We have revised § 98.233(d)(10) to read as follows in th e final rule:

“ Calculate annual mass CO 2 emissions using calculations in paragraph (v) of this s ection .”

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 94
Comment: Proposed Citation Reference: Acid Gas Removal §98.236(d)(1)(vi) , Proposed Rule Text: Sub

- basin ID (for the onshore petroleum and natural gas production industry segment only). It is not clear if this requirement refers to the AGR unit itself or the wells that supply gas to the unit. “Sub

- basin” is the designated Basin , county and formation combination. Reporting the formation type is not relevant for surface equipment, particularly since very few AGR units are not treating co

- mingled gas streams. API requests that EPA drop this as a reporting element. If EPA insists on keeping this reporting requirement, the reporter should be able to select a single sub

- basin ID that best represents the wells that supply gas to the unit. Response: It was the EPA’s intent to gather the sub

- basin ID for wells that supply gas to the AGR unit to improve verification of reported emissions. The EPA agrees with the commenter that it may be unclear how the requirement would apply to AGR units that treat co

- mingled gas stream s . Therefore, we have revised § 98.236(d)(1)( vi ) to clarify that the r eporter may select the sub

- basin ID that best represents the wells that supply gas to the unit.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA)

11Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A3 Comment Excerp t Number: 19
Comment: Acid gas removal vent transferred offsite: EPA revised the reporting requirement 98.236(d)(1)(iv) (citation in the proposed rule) such that if any emissions from the AGR unit were recovered and transferred outside of the facility, this quantity must be reported under Subpart W. We oppose this change as this quantity is already reported under Subpart PP, making this reporting requirement redundant, which wastes time and effort by reporters. Response: The commenter is correct that su bpart W required reporters to report the annual quantity of CO 2 that was recovered from the AGR unit and transferred outside the facility under subpart PP. The EPA inadvertently omitted the clause “under subpart PP of this part” at the end of this paragraph in the proposed amendments. In the final rule , the EPA is clarifying in § 98.236(d)(1)(iv) that the annual quantity of CO 2 that was recovered from the AGR unit and transferred outside the facilit y must be reported under subpart PP

. This is consistent with the historical reporting of recovered CO 2 quantities from AGR units and prevents duplicative reporting of the recovered CO 2 quantities under both subparts W and PP

.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0091

- A2 Comment Excerpt Number: 5
Comment: Proposed EPA Amendment: For acid gas removal (AGR) vents, revise Equations W

- 4A and W

- 4B to clarify that the volumetr ic fractions of CO2 in natural gas flowing into / out of the AGR be annual averages. Williams currently calculates the annual average for these variables and supports the proposed, clarifying amendment. Response: The EPA thanks the commenter for their sup port. These revisions are finalized as proposed.



### 5.0 Dehydrators
5.1 M inor R evisions to C alculation M ethods (e.g., accounting for venting to vapor recovery or flare)

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Docume nt Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0073

- A1 Comment Excerpt Number: 5

12Comment: EPA is proposing to revise estimation methodologies for dehydration units and blowdown vents. EPA is proposing to revise the dehydrator vent source estimations by adjusting the emissions calculation to account for venting to a vapor recovery system or a flare. This would result in a more accurate emissions determination for these sources. We support these changes which will result in a more accurate emissions determ ination for these sources. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 46
Comment: Dehydrator vents , Revisions to §98.233(e)(5): EPA proposes to include provisions to adjust emissions downward where dehydrator vents are routed to a vapor recovery system. Comment: API supports this revision for dehydrators owned and operated by the reporter. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Do cument Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 4 7
Comment: Dehydrator vents , Revisions to §98.233(e): EPA proposes editorial revisions to clarify the calculation methods for desiccant dehydrators. This includes reordering pa ragraphs (3), (4), and (5) to make it more clear the emissions from desiccant dehydrators are also adjusted where emissions are routed to a VRU or flare. API supports these revisions. Response: The EPA thanks the commenter for their support. These revisio ns are finalized as proposed.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A3 Comment Excerpt Number: 16

13Comment: Incorrect terminology for dehydrators : EPA proposes various changes to dehydrator terminology. For example, in the current rule, 98.233(e)(1) reads “ Calculation Methodology 1

. Calculate annual mass emissions from dehydrator vents with annual average daily throughput greater than or equal to 0.4 mi llion standard cubic feet per day using a software program ...” In the proposed rule, EPA proposes to change this to “ Calculation Method 1. Calculate annual mass emissions from absorbent dehydrators that have an annual average of daily natural gas throughput that is greater than or equal to 0.4 million standard cubic feet per day by using a software program ...” [emphasis added]. EPA does not explain why this change was made, and it’s unclear if EPA is trying to include equipment other than glycol dehydrators. Wi th no supporting explanation, we assume that EPA is merely changing terminology and not changing the scope of equipment covered here. If this is indeed the case, EPA should not use the term

“ absorbent dehydrator ”. This is not a term used by industry, it is not defined in the rule, and it may cause confusion with desiccant dehydrator requirements as they do use an absorbent. We propose the following language changes: 98.233(e)(1) Calculation Method 1. Calculate annual mass emissions from absorbent glycol deh ydrators that have an annual average of daily natural gas throughput that is greater than or equal to 0.4 million standard cubic feet per day by using a software program... 98.233(e)(6)(i) Use the dehydrator vent volume and gas composition as determined in paragraphs (e)(1) or (e)(2) of this section for absorbent glycol dehydrators. Use the dehydrator vent volume and gas composition as determined in paragraphs (e)(3) and (e)( 4) of this section for dehydrators that use desiccant. 98.236(e) Dehydrators. You must indicate whether your facility contains any of the following equipment: absorbent glycol dehydrators with an annual average daily natural gas throughput greater than or equal to 0.4 million standard cubic feet per day, glycol dehydrators with an annual average daily natural gas throughput less than 0.4 million standard cubic feet per day, and dehydrators that use desiccant. If your facility contains any of the equipment listed in this paragraph (e), then you must report the applicable information in paragraphs (e)(1) through (e)(3). 98.236(e) ( 1) For each absorbent glycol dehydrator that has an annual average daily natural gas throughput greater than or equal to 0.4 million standard cubic feet per day (as specified in § 98.233(e)(1)), you must report the information specified in paragraphs (e)(1)(i) through (e)(1)(xviii)
R esponse: We proposed these revisions primarily to clarify that the 0.4 million standard cubic feet (MMscf) per day throughput relates to the natural gas throughput of the dehydrator for determining the applicability of Calculation Method 1, not the throug hput of the vent itself. The EPA agrees with the commenter that the terminology “absorbent dehydrators ” may cause confusion since desi c cant dehydrators use an absorbent . We have revised § 98.233(e)(1) and § 98.236(e) and (e)(1) to clarify that these provisio ns apply to “glycol dehydrators ”

. We have also revised § 98.233(e)(6)(i) to read “ Use the dehydrator vent volume and gas composition as determined in paragraphs (e)(1) through (e)(5) of this section, as applicable”, so this paragraph no longer uses the term “absorbent dehydrators”. See Section II.B.3 of the preamble to the final rule for additional discussion responding to this comment.

14

### 5.2 Comments on other minor revisions and restructuring of reporting requirements for dehydrators

Commenter Name: Karin Ritte r Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 96
Comment: Proposed Citation Reference for Dehydrators: §98.236(e)(1)(xviii), Proposed Rule Text: Sub

- basin ID (for the onshore petroleum and natural gas production industry segment only). It is not clear if this requirement refers to the dehydrator itself or the wells that supply gas to the unit. “Sub

- basin” is the designated Basin, county and formation combinatio n. Reporting the formation type is not relevant for surface equipment, particularly since very few dehydrators are not treating co

- mingled gas streams. API requests that EPA drop this as a reporting element. If EPA insists on keeping this reporting require ment, the reporter should be able to select a single sub

- basin ID that best represents the wells that supply gas to the dehydrator. Response: It was the EPA's intent to gather the sub

- basin ID for wells that supply gas to the dehydrator to improve verific a tion of reported emissions. The EPA agrees with the commenter that it may be unclear how the requirement would apply to dehydrators that treat co

- mingled gas stream s . Therefore, we have revised § 98.236( e )(1)( xviii ) to clarify that the reporter may select the sub

- basin ID that best represents the wells that supply gas to the unit.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A3 Comment Excerpt Number: 17
Comme nt: Dehydrator emissions reporting

– control devices for large dehys. 98.236(e)(1)(xvii) does not seem to contemplate dehydrator emissions that are routed to vapor recovery. While 98.236(e)(xv) includes the "yes

- or
- no" reporting element of "Whether any de hydrator emissions are vented to a vapor recovery device", there is no emissions reporting requirement that contemplates this scenario. The following changes are suggested: 98.236(e)(1)(xvii) Whether any dehydrator emissions are vented to the atmosphere wi thout being routed to a flare or regenerator firebox/fire tubes or to a vapor recovery device . If any emissions are not routed to a flare or regenerator firebox/fire tubes or to a vapor recovery device , then you must report the information specified in par agraphs (e)(1)(xvii)(A) and (e)(1)(xvii)(B) of this section for those emissions from the dehydrator.

1598.236(e)(1)(xvii)(A) Annual CO 2 emissions, in metric tons CO2, for the dehydrator when not venting to a flare or regenerator firebox/fire tubes or vapor recovery device , calculated according to § 98.233(e)(1) , and (e)(5), and (e)(6) as applicable

. 98.236(e)(1)(xvii)(B) Annual CH 4 emissions, in metric tons CH 4 , for the dehydrator when not venting to a flare or regenerator firebox/fire tubes or vapor recove ry device , calculated according to § 98.233(e)(1) , and (e)(5), and (e)(6) as applicable

. Response: The commenter may have misinterpreted the reporting requirements in § 98.236(e)(1)(xvii)

. The emissions required to be reported in § 98.233(e)(1)(xvii) (A) an d (B) are to be corrected to account for recovery as provided in § 98.233(e)(5), so the reported emissions will not include emissions associated with vapors that are recovered

. W e intentionally require reporting under § 98.233(e)(1)(xvii) for all emissions not routed to a flare or regenerator firebox/fire tubes to ensure all units report emissions

. If a facility recovers all vapors not routed to a flare or regenerator firebox/fire tubes, then the facility would report “0” (zero) for their emissions in § 98.23 3(e)(1)(xvii)(A) and (B)

. R eporting in this way helps in the verification process to distinguish between facilities that may have inadvertently not reported emissions and facilities that have no uncontrolled atmospheric emissions from their dehydrators.
W e have not included the commenter's reference to §98.233(e)(6); §98.233(e)(6) refers to calculation of annual emissions from dehydrator vents routed to a flares or regenerator fire

box/fire tubes. These emissions are reported under §98.236(e)(1)(xvi). We b elieve that the description of the emissions to be reported §98.233(e)(1)(xvii) clearly indicates the emissions to be reported in the §98.236(e)(1)(xvi) (A) and (B) are to exclude emissions that are routed to a flares or regenerator fire

- box/fire tubes.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A3 Comment Excerpt Number: 32
Comment: Dehydrator emissions reporting

– future e

- GGRT issues: 98.236(e)(2)(iii) s ays, “... If any dehydrators reported in paragraph (e)(2)(i) of this section were vented to a control device other than a vapor recovery device or a flare or regenerator firebox/fire tubes, then you must specify the type of control device and the number of de hydrators at the facility that were vented to each type of control device .” Note that EPA will need to program this into e

- GGRT as a blank text field to be populated by the reporter; historically, these types of blank text fields have been avoided by EPA. In addition, the three types of control (vapor recovery, flare, regenerator) should cover the vast majority of vented emissions that are controlled. Response: The EPA thanks the commenter for their input. The EPA will consider this comment in future imple mentations of e

- GGRT.

16Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A3 Comment Excerpt Number: 33
Comment: Dehydrator emissions reporting

– failure to account for multiple emission points: For the reporting requirements for small dehydrators in 98.236(e)(2), EPA fails to account for the fact that sometimes a single dehydrator can have multiple emission points and that these emission points are often hand led differently (e.g., one vent may be routed to vapor recovery while another vent may be routed to flare). The following changes are therefore needed, and they also conform with 98.236(e)(1). Because the same dehydrat or can have different means of emissio ns routing, we encourage EPA to consider whether or not the reporting requirements for small glycol dehydrators need to be changed at all. 98.236(e)(2)(ii) Whether any dehydrators reported in paragraph (e)(2)(i) of this section dehydrator emissions were ve nted to a vapor recovery device. If any dehydrators reported in paragraph (e)(2)(i) of this section dehydrator emissions were vented to a vapor recovery device, then you must report the total number of dehydrators at the facility that vented to a vapor
rec overy device. 98.236(e)(2)(iii) Whether any dehydrators reported in paragraph (e)(2)(i) of this section dehydrator emissions were vented to a control device other than a vapor recovery device or a flare or regenerator firebox/fire tubes. If any dehydrator s reported in paragraph (e)(2)(i) of this section dehydrator emissions were vented to a control device other than a vapor recovery device or a flare or regenerator firebox/fire tubes, then you must specify the type of control device and the number of dehyd rators at the facility that were vented to each type of control device. 98.236(e)(2)(iv) Whether any dehydrators reported in paragraph (e)(2)(i) of this section dehydrator emissions were vented to a flare or regenerator firebox/fire tubes. If any dehydrators reported in paragraph (e)(2)(i) of this section dehydrator emissions were vented to a flare or regenerator firebox/fire tubes, then you must report the information specified in paragraphs (e)(2)(iv)(A) through (e)(2)(iv)(D) of this section.
98 .236(e)(2)(v) For dehydrators reported in paragraph (e)(2)(i) of this section dehydrator emissions that were not vented to a flare or regenerator firebox/fire tubes, report the information specified in paragraphs (e)(2)(v)(A) and (e)(2)(v)(B) of this secti on. Additionally, the proposed language further confuses possible operating scenarios in 98.236(e)(2)(v)(A) and (B), as well as in 98.236(e)(3)(ii) and (iii). These requirements reference calculations that only account for vapor recovery. However, the rep orting requirement applies broadly to any dehydrator emissions that were not vented to a flare or regenerator firebox/fire tubes. In other words, if an alternative control device is used (as contemplated in 98.236(e)(2)(iii)), there is no emissions reporti ng requirement that accounts for such a configuration. Again, we encourage EPA to consider whether or not the reporting requirements for small glycol dehydrators and desiccant dehydrators need to be changed at all.

17Response: The EPA agrees with the commen ter that the proposed reporting requirements did not acc ount for small dehydrators rout ed to multiple emission points. We have revised § 98.233(e)(2)(ii) through ( v ) as suggested by the commenter. We are clarifying in this response that we intended for the emissions reported in § 98.236(e)(1)(xvii)(A) and (B), ( e)(2)(v)(A) and (B), and (e)(3)(ii) and (iii) would not include emissions that are routed to a flare or regenerator firebox/fire tubes

. We consider the language in the introductory paragraphs in § 98.2 36(e)(1)(xvii) and ( e)(2)(v) as well and the language in (e)(3)(ii) and (iii) to clearly indicate that the emissions reported according to these requirements do not include emissions routed to a flare or regenerator firebox/fire tubes even though the emiss ions calculated according §98.233(e)(1) through (e)(5) do not directly adjust for the portion of the emissions that are routed to a flare or regenerator firebox/fire tubes.
We are not amending the reporting requirements to adjust the emissions for control systems other than vapor recovery systems, flares or regenerator firebox/fire because we have not provided a calculation methodology for these emissions under §98.233(e). If a significant number of “other control systems” are reported, the EPA may consider amendments in a future rulemaking to account for these alternate configurations.



### 6.0 Well Venting for Liquids Unloading
6.1 Revisions to Calculation Method 1 to allow for annualizing venting data (Eq uatio ns W
- 7A and W
- 7B)

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 49
Comment: Well venting for liquids unloading: Revisions to §98.233(f)(1): EPA is proposing to modify the requirements for li quids unloading to accommodate the revisions requested by API to address situations where it is not possible to gather vent hours and the number of unloadings from January 1st to December 31st. API supports these revisions. Response: The EPA thanks the co mmenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 76

18Comment: Monitoring and QA/QC requirements: Revisions to §98.234(h): EPA is proposing to add a new paragraph addressing the monitoring period for liquids unloading: For well venting for liquids unloading, if a monitoring period other than the full calendar year is used to determine the cumulative amount of time in hours of venting for each well (the term “Tp” in Equation W

- 7A and W

- 7B of § 98.233) or the number of unloading events per well (the term “Vp” in Equations W

- 8 and W

- 9 of § 98.233), then the monitoring per iod must begin before February 1 of the reporting year and must not end before December 1 of the reporting year. The end of one monitoring period must immediately precede the start of the next monitoring period for the next reporting year. All production d ays must be monitored and all venting accounted for. API supports this revision which relates to changes made in §98.233(f)(1). Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin R itter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

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- A2 Comment Excerpt Number: 3
Comment: Well Venting for Liquids Unloading: API supports EPA’s proposal to revise the calculation and repor ting requirements for well venting from liquids unloading to allow for annualizing venting data for facilities that calculate emissions using a flow meter (Calculation Method 1). Response: The EPA thanks the commenter for their support. These revisions ar e finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

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- A2 Comment Excerpt Number: 50
Comment: Well venting for liquids unloading:
Revisions to §98.233(f)(1): EPA is proposing to revise Equation W

- 7 (Equation W

- 7A in the proposed rule) to pull the average flow rate term (FR) outside the summation. This revision makes the equation consistent with the definition of FR, which is the average flow
r ate for all measured wells of the same tubing diameter and pressure group combination in a sub

basin. Note, however, the flowrate for FR is defined as being in actua l conditions. Industry

19practice is to measure gas flow rates in standard conditions. In add ition, Equation W

- 7 is inconsistent with Equations W

- 8 and W

- 9 which both result in emissions at standard conditions. API requests that Equation W

- 7 be revised to reflect that the FR term and the resulting emissions are in standard conditions. Response: T he EPA is clarifying in the introductory text at § 98.233 and § 98.236 that the use of systems that automatically correct to standard conditions is allowed . This allows reporters that do measure actual volumes to use the equations as presented, but it allows reporters that determine flow volumes at standard conditions to use these measurements directly. See Section II.B.13 of the preamble to the final rule f or additional discussion responding to this comment

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

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- 2011

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- A2 Comment Excerpt Number: 18
Comment: Gas Flow Rate Measu rements. In discussions with EPA, API has emphasized the need to use industry standard conditions for gas flow and volume measurements. API urges EPA to revise the terms for Equations W

- 3, W

- 4A, W

- 4B, W

- 7, W

- 17A, W

- 17B, W

- 39A, and W

- 39B to reflect that mea sured or estimated gas volumes used in these equations and the resulting emissions are in standard conditions. This is particularly the case for Equation W

- 34 because it makes no sense to take a gas flow rate already determined in standard conditions to co nvert it to actual conditions just to apply a required estimation methodology which, in turn, will again convert it back to standard conditions per the rule requirements. Response: The EPA is clarifying in the introductory text at § 98.233 and § 98.236 that the use of systems that automatically correct to standard conditions is allowed . This allows reporters that do measure actual volumes to use the equations as presented, but it allows reporters that determine flow volumes at standard conditions to use thes e measurements directly. See Section II.B.13 of the preamble to the final rule for additional discussion responding to this comment

.

Commenter Name: Carrie B. Crumpton Commenter Affiliation: CONSOL Energy, Inc. Document Control Number: EPA

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- A1 Comment Excerpt Number: 7
Comment: Requiring the conversion of gas flow rates from "standard conditions" to "actual conditions" when applying required estimation methodology is burdensome and overly complicated. These estimations then have to be converted back into standard conditions for reporting under the regulatory requirements. Since instrumentation used in the industry typically measures gas flow rates in standard conditions, CONSOL request the EPA to revise Equations W

- 3, W

- 4A, W

- 4B, W

- 7, W

- 17A, W

- 17B, W

- 34, W

- 39A, and W

- 39B to reflect that the

20measured gas volumes and/or estimated gas volumes used in these equations, and the resulting emissions, are in standard conditions to better meet reporting requirements and consistency. Response : The EPA is clarifying in the introductory text at § 98.233 and § 98.236 that the use of systems that automatically correct to standard conditions is allowed . This allows reporters that do measure actual volumes to use the equations as presented, but it allows reporters that determine flow volumes at standard conditions to use these measurements directly. See Section II.B.13 of the preamble to the final rule f or additional discussion responding to this comment

. 

### 6.2 Revisions to Calculation Method 1 and 2 to separate calculation of emissions from wells with plunger lifts and wells without plunger lifts

Commenter Name: Karin Ritter Commenter Affiliation: American P etroleum Institute (API) Document Control Number: EPA

- HQ

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- 2011

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- A2 Comment Excerpt Number: 48
Comment: Well venting for liquids unloading: Revisions to §98.233(f)(1): EPA proposes to separate the calculation and reporting of emissions from w ells that have plunger lifts and wells that do not. This applies to Calculation Method 1. “...For any tubing diameter group and pressure group combination in a sub

- basin where liquids unloading occurs both with and without plunger lifts, Equation W

- 7A will b e used twice, once for wells with plunger lifts and once for wells without plunger lifts.” API supports the added transparency provided by this revision. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

- HQ

- OAR

- 2011

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- 0087

- A2 Comment Excerpt Number: 7
Comment: A variety of analyses have utilized Subpart W data to help deepen understanding of emissions from the oil and gas sector, including the Annual Inventory of U.S. Greenhouse Gas Emissions and Sinks and efforts by academics and other researchers to assess emissions, which have provided essential independent information about emissions fr om this sector. We specifically support many of the proposed revisions to Subpart W

— listed below

— that would enhance the ability of the public and policy makers to use the data in future contexts like these. We also respectfully suggest additional changes t hat would support these important goals.

21• Well venting for liquids unloading. EPA has also proposed helpful changes regarding liquids unloading. 22 In particular, the provisions will result in more disaggregated data and facilitate a better understanding of the factors affecting emissions from wells with and without plunger lifts. EPA’s revised description of the reporting requirements is also much clearer. Footnotes:

22 Fed. Reg. at 13,398

– 99. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed. 

### 6.3 Revisions to term "SPp" ed (well shut
- in pressure or surface pressure) of Eq uation W
- 8

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

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- 2011

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- A2 Comment Excerpt Number: 51
Comment: Well venting for liquids unloading , Revisions to §98.233(f)(2): EPA is proposing to modify the term SPp in Equation W

- 8 to provide an alternative method for determining the casing pressure: If casing pressure is not available for each well, you may determine the casing pressure by multiplying the tubing pressure of each well with a ratio of casing pressure to tubing pressure from a well in the same sub

- basin for which the casing pressure is known. The tubing pressure must be measured during gas flow to a flow

- line. The shut

- in pressure, surface pressure, or casing pressure must be determined just prior to liquids unloading when the well production is impeded by liquids loading or closed to the flow

- line by surface valves. API supports the added flexibility provided by this revision. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed. 

### 6.4 Comments on other minor revisions and restructuring of reporting require ments for well venting for liquids unloading

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

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- A2 Comment Excerpt Number: 97
Comment: Proposed Citation Reference for Liquids Unloading: §98.236(f)(1)(xi) and (f)(1)(xi)(A), Proposed Rule Text: (xi) For each well tubing diameter group and pressure group combination, you must report the information specified in paragraphs (f)(1)(xi)(A) through

22(f)(1)(xi)(E) of this sec tion for each individual well not using a plunger lift that was tested during the year. (A) API number of tested well. API opposes reporting the API well number for tested wells as this is not directly relevant to quantifying emissions. Response: The EPA is requiring the reporting of API Well Numbers for tested wells to improve data quality by enabling identification of these wells. The API number of the tested well provides state, county, and location information that informs the verification and characte rization of reported data. Collection of this data will allow the EPA to link the GHGRP data to other databases to more easily match the data reported under the GHGRP with other data sources. This data element is similar to the data collected under other s ubparts of Part 98 which is useful for verification and characterization of reported data. For these reasons, EPA is retaining the requirement to report API Well Numbers for tested wells in the final rule.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

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- 2011

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- A2 Comment Excerpt Number: 98
Comment: Proposed Citation Reference: §98.236(f)(1)(xii) and (f)(1)(xii)(A), Proposed Rule Text: (xii) For each well tubing diameter group and pressure group combination, you must report the information specified in paragraphs (f)(1)(xii)(A) through (f)(1)(xii)(E) of this section for each individual well using a plunger lift that was tested during the year. (A) The API well nu mber. API opposes reporting the API well number for tested wells as this is not directly relevant to quantifying emissions Response: See response to comment EPA

- HQ

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- 2011

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- 0084

- A2, Excerpt 97.

Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

- HQ

- OAR

- 2011

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- 0087

- A2 Comment Excerpt Number: 8
Comment: We respectfully urge the Agency to make liquids unloading data more usable by requiring reporting of the total number of unloading event s in methods 2 and 3. 23 Currently, these two methods only report the number of venting wells in each sub

- basin category, and this data cannot be used to estimate average emissions per unloading event or average venting frequency per well.

23 40 C.F.R. § 98 .236.

23Response: The EPA thanks the commenter for their suggestion

. Previously, the reporting of the cumulative number of unloadings vented to the atmosphere was deferred. In the 2014 proposed amendments at § 98.236(f)(2)(v) , we proposed to require the repo rting of the cumulative number of unloading events vented to the atmosphere for each well, aggregated across all wells for each sub

- basin for which Calculation Method 2 or 3 was used. According to the proposed requirement at § 98.236(f)(2), reporters are re quired to report this aggregate number of unloading events separately for each calculation method . Therefore, the proposed rule already address es the commenter’s issue; we are finalizing these revisions are proposed

.


### 7.0 Gas Well Completions and Workovers wit h Hydraulic Fracturing
7.1 Comments on proposed definitions for "reduced emissions completion," "reduced emissions workover," and "well completions"

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

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- 2011

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- 0084

- A2 Comment Excerpt Number: 1
Comment: Definitions of Well Completions and Workovers : API generally supports EPA’s proposal with respect to gas well completions and workovers. Specifically, API supports the proposal to a mend the definition of “well completions” to delete the term “re

- fracture” where this term applies to an already producing well and is considered a well workover, not a well completion for the purposes of part 98. This revision will avoid confusion regardi ng whether a re
- fracture is a completion or a workover in the context of Subpart W. Response: The EPA thanks the commenter for their support. The EPA is finalizing the definition of “well completions” in § 98.6 to delete the term "re

- fracture" as proposed

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

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- A2 Comment Excerpt Number: 35
Comment: (§98.6) EPA is proposing to revise the definition of well completions. Well completions means the process that allows for the flow of petroleum or natural gas from newly drilled wells to expel drilling and reservoir fluids and test the reservoir flow chara cteristics, steps which may vent produced gas to the atmosphere via an open pit or tank. Well completion also involves connecting the well bore to the reservoir, which may include treating the formation or installing tubing, packer(s), or lifting equipment , steps that do not significantly vent natural gas to the atmosphere. This process may also include high rate flowback of injected gas, water, oil, and proppant used to fracture or re
- fractur e and prop open new fractures in existing lower

24permeability gas reservoirs, steps that may vent large quantities of produced gas to the atmosphere. In addition to activities that are either part of a well “completion” or “workover”, there are many activities that are merely “routine operations / surveillance / maintena nce” that are conducted on a well with the production tree installed after the initial completion or workover event. For many activities, the timing of the action is what causes an activity to be classified as either a “completion” or a “workover.” If the operation is done during the original drilling, it is a “completion.” If it is done at some point later on a well that is already producing 12 , it is a “workover.” In order to improve the clarity of the classifications of well

- site activities, API requests the following amendments to the definitions of “completions” and “workover” in 40 CFR §98.6 to improve clarity and ensure consistency with definitions the industry is using under other regulatory programs: Well completions mean the process of making a new oil or natural gas well ready for production. It that allows for the flow of petroleum or natural gas from newly drilled wells to expel drilling and reservoir fluids and test the reservoir flow characteristics steps which may vent produced gas to the atmos phere via an open pit or tank. Well completion and a lso involves connecting the well bore to the reservoir, which may include treating the formation or installing tubing, packer(s), or lifting equipment

. steps that do not significantly vent natural gas to the atmosphere. This process may also include high

- rate flowback of injected gas, water, oil, fracture fluids and some proppant along with formation fluids such as oil, gas and produced water

. used to fracture or re
- fracture and prop open new fractures in existing lower permeability gas reservoirs, steps that may vent large quantities of produced gas to the atmosphere. Venting or flaring of gas may also occur during this process.
Well workover means the work co nducted on already producing wells with a rig or coiled tubing unit after the initial completion is over. Such process(es) of may include performing one or more of a variety of remedial operations on producing petroleum and natural gas wells to try to inc rease production or return the well to its normal production rate. This process also includes high

- rate flowback of injected fracture fluids and some proppant along with formation fluids such as oil, gas, and produced water gas, water, oil, and proppant us ed to re

- fracture and prop

open new fractures in existing low permeability gas reservoirs or recomplete and existing well to a new production zone/horizon. Venting or flaring of gas may also occur during this process.
A well workover does not include rout ine maintenance activities that are performed on the well with the tree installed (See 30 CFR Part 250.601 Definitions for further details). Such routine activities may include maintenance, repair, or replacement of equipment such as rods, pumps, tubing, p ackers, or other mechanical devices.
Footnote s :

12 Refer to EPA’s response to V. Bruce Thompson of the American Exploration & Production Council in the Subpart W Response to Comments Part 2, dated November 2010 (page 1698), Comment Number: EPA

- HQ

- OAR

- 2009

- 0923

- 1040

- 17.

25Response: The EPA is finalizing the definition of “well completions” in § 98.6 to delete the term "re

- fracture" as proposed. As discussed in the preamble to the proposed rule at 70 FR 13399, the term “re

- fracture” onl y applies to well workov ers, so we only intended to remove this improper reference to “re

- fracture” in the proposed revision. The commenter’s suggested revisions for “well completion” appear to be a complete re

- write of the definition and, as such, go es beyond the scope of the pr oposed revisions . This significant re

- write of the definition would need to go through full public review and comment. Therefore, we are not making any additional revisions to the definition of “well completions” based on these comments. The EPA did not propose to revise the definition of “well workovers”. As such, the suggested revisions to the definition of “well workovers” commen t is beyond the scope of this rulemaking. We are not amending the definition of “well workovers” in this final rule.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 40
Comment: (§98.238) New definition for Reduced Emissions Completion (REC)
. Reduced emissions completion means a well completion following hydraulic fracturing where gas flowback that is otherwise vented is captured, clea ned, and routed to the flow line or collection system, re

- injected into the well or another well, used as an on

- site fuel source, or used for other useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere. EPA is proposing to use the same regulatory definition for well completions as currently used for 40 CFR Part 60 Subpart OOOO (Quad O). However, Quad O contains additional provisions that expand the definition and EPA has issued guidance (See attached lett er to Matt Todd from Peter Tsirigotis dated September 28, 2012) 13 clarifying this definition for Quad O to include brief periods of venting and to include flaring of flowback gas, but has not yet codified those changes. API’s understanding is that the pend ing revisions to Quad O will address this issue in a manner similar to what is proposed below. As proposed, the Subpart W definition would result in no RECs reported due to the phrase “no direct release to the atmosphere”. API has explained to EPA on numer ous occasions that there is a small amount of gas released during the initial flowback before sufficient gas to operate a separator is available. In addition, the Subpart W definition does not provide for flaring to occur on wells with REC. EPA has modifie d the calculation approach for completions and workovers with hydraulic fracturing in this proposed rule to address the small amount of venting during initial flowback and provides provisions for flaring associated with gas well completions and workovers. Therefore, EPA must also modify the definition for reduced emission completions. API urges EPA to adopt these revisions for Subpart W. “Reduced emissions completion (REC) means a well completion following hydraulic fracturing where gas flowback emissions f rom the gas outlet of the separator that is are otherwise vented is are captured, cleaned, and routed to the flow line or collection system, re

- injected into

26the well or another well, used as an on

- site fuel source, or used for other useful purpose that a purchased fuel or raw material would serve, with minimal no direct venting release to the atmosphere. Short periods of flaring during a REC may occur .”
Footnote s :

13 API references the additional guidance contained in the letter to Matt Todd (API) from Peter Tsirigotis (EPA), dated September 28, 2012. Response: The EPA revising the definitions of “reduced emissions completion” and “reduced emissions workover” to clarify the venting and flaring activities that may occur as suggested by the commenter

. See Section II.B.5 of the preamble to the final rule for additional discussion responding to this comment. 

### 7.2 Revisions to Eq uations W
- 10A and W
- 10B

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

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- A2 Comment Excerpt Number: 52
Comment: Well venting during completions and workovers with hydraulic fracturing: Revisions to §98.233(g): EPA is proposing to modify Equation W

- 10A as requested by API to remove the sales gas ter m and to include an estimate for the initial cleanup stage of the flowback where there is insufficient gas. EPA is also proposing to modify the terms for FRMs to be based on the average flowback and PRs,p to be based on the average production flow. Equatio n W

- 10B is modified to include the estimated emissions for the initial cleanup stage of the flowback. The proposed revisions accommodate the primary issues raised by API and API strongly supports these revisions. However, other issues remain with the equat ions for Calculation Method 2. API looks forward to continuing discussions with EPA on these issues. Response: The EPA thanks the commenter for their support. The revisions to Equations W

- 10A and W

- 10B are being finalized as proposed

.

Commenter Name: K arin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

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- A2 Comment Excerpt Number: 101
Comment: Proposed Citation Reference for Completions and Workovers with Hydraulic Fracturing: §98.23 6(g)(5) and §98.236(g)(5)(i), Proposed Rule Text: (5) If you used Equation W

- 10A to calculate annual volumetric total gas emissions, then you must report the information specified in paragraphs (g)(5)(i)and (g)(5)(ii) of this section.

27(i) Cumulative backflow time, in hours, for each sub basin (“Tp” in Equation W

- 10A). Comment: In the proposed rule, Equation W

- 10A under 98.233(g) uses the terms Tp,s and Tp,i to refer to the cumulative times for the two stages of flowback represented in the equation. Th e reporting requirements here do not use the same terminology. Response: The EPA agrees with the commenter that the terminology should be consistent between §98.233 and §98.236(g)(5)(i). W e have revised §98.236(g)( 5)(i) to clarify that facilities must report the flowback time after sufficient quantities of gas are present to enable separation. The first sentence in §98.236(g)(5)(i) reads as follows: “ Cumulative flowback time, in hours, for each sub

- basin , from when gas is first detected until sufficient quanti ti es are present to enable separation, and the cumulative flowback time, in hours, for each sub

- basin, after sufficient quantities of gas are present to enable separation (“T p,i ” and “T p,s ” in Equation W

- 10A)

. ”

Commenter Name: V. Bruce Thompson Commenter Affiliation: American Exploration & Production Council (AXPC) Document Control Number: EPA

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- A2 Comment Excerpt Number: 6
Comment: AXPC and the Alliance appreciate EPA’s recognition th at there are two distinct periods of flowback as defined by the rule. However, we do not support the addition of an emissions term in the equation for the period of flowback prior to separation. We strongly believe that emissions from this period are de mi nimus, as stated by EPA itself in their September 28, 2012 letter to API, stating that “Initially, the flowback consists of water, sand and fracturing fluids”. While there may be small amounts of entrained gas in the fluids that are returned to the surface prior to separation, the quantity is very small and not detectable. In practice, as soon as gas is detected it is routed to the separator for flaring or recovery, reducing the term Tp,i to zero and making that portion of the equation irrelevant and unnece ssary. Additionally, if fluids are not able to be routed to the separator as soon as gas is detected then the volume of gas during that period will be far less than half of the post

‐ separation flow rate as the volume of gas will continue to increase during the initial stages of flowback. We urge EPA to remove these pre

‐ separation emission terms from equations W

‐ 10A and W

‐ 10B. Response: The EPA has decided to retain the proposed calculation and reporting of pre

separation emissions in E quations W

- 10A and W

- 10B. For cases where fluids are routed to the separator immediately upon first detection of gas, the equation correctly applies zero emissions to the initial flowback period. However, f or cases where fluids are not immediately routed to the separator upon first gas detection, there are emissions associated with the initial flowback period that would not be accounted for without the initial flowback term

. T he commenter asserts that the volume of gas during the initial flowback period will be “

... far less than half of the post

‐ separation flow rate as the volume of gas will continue to increase during the initial stages of flowback ”; h owever, the factor of one

- half was added specifically to address this increase. The factor of one

- half assumes this increase is li near over the period of initial gas detection to the time flowback is diverted to the separator. The commenter offered no data or alternative assumption that would provide a better estimate of the emissions during the initial flowback

28period. Consequently, the revisions to Equations W

- 10A and W

- 10B are being finalized as proposed

. 

### 7.3 Clarifications to § 98.233(g)(1) and (g)(2)

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

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- A2 Comment Excerpt Number: 55
Comment: Well venting during completions and workovers with hydraulic fracturing , Revisions to §98.233(g)(2): EPA is proposing to expand the definition of well type combination. A well type combination is a unique comb ination of the parameters listed in paragraphs (g)(2)(i) through (g)(2)(iii) of this section. (i) Vertical or horizontal (directional drilling). (ii) With flaring or without flaring. (iii) Reduced emission completion/workover or not reduced emission comple tion/workover. For reporters using Equation 10

- A, the existing rule specifies the number of measurements required for each sub

- basin and well type (vertical or horizontal) combination with a maximum number of combinations that need to be measured in each c ounty of 10 (5 formation types and two well types). The proposed changes increase this theoretical number of combinations to 40 in each county (5 formation types X 8 possible combinations of well types). Coupled with the new requirement to measure or calcu late completions and workovers separately in each sub

basin/well

- type combination the theoretical number of measurements or calculation combinations is raised to 80 in each county. This effectively quadruples the number of potential measurement or calculat ion requirements for completions or workovers, separately, in each county. Additionally, whether a well will clean

- up quickly with no need to flare or vent is not able to be determined prior to beginning the actual flowback and cannot be a criteria for pla nning which wells to measure or collect information to enable calculating the flowback volume. Although full implementation of NSPS Quad O will sharply reduce the number of flowbacks where gas is not flared and/or REC’s are not preformed (in January 2015), the exclusions provided still render these options possible. Besides the obvious cost and burden implications of quadrupling the number of possible combinations requiring measurement or calculation in each county, this will be a scheduling nightmare for o perators

– particularly since prior determination of whether a well will require flaring is not possible. Recommendation 1: EPA should modify the proposed language as follows: (2) The volume of CO2 or N2 injected into the well reservoir during energized hy draulic fractures will be measured using an appropriate meter as described in 98.234(b) or using receipts of gas purchases that are used for the energized fracture job. For paragraphs (g) introductory text and (g)(1) of this section, measurements and calcu lations are completed separately for workovers and completions per sub

- basin and well type combination. A well type combination is a unique combination of the parameters listed in paragraph s (g)(2)(i) through (g)(2)(iii) of this section. (i) Calculate gas volume at standard conditions using calculations in paragraph (t) of this section.

29(i) Vertical or horizontal (directional drilling). (ii) [Reserved]With flaring or without flaring. (iii) Reduced emission completion/workover or not reduced emission complet ion/workover. Recommendation 2: To achieve transparency regarding the number of completions and workovers that flare or not and that employ REC’s or don’t employ REC’s, EPA should expand the reporting requirements in 98.236(g)(3) as follows:

• (3) Number of completions or workovers in the category.

• (i) Number of completions or workovers that employed a reduced emission completion (REC)

• (A) Number of completions or workovers that flared gas with no venting (excluding the initial flowback period)

• (B) Number of completions or workovers that both flared gas and vented gas (excluding the initial flowback period)

• (C) Number of completions or workovers that vented gas with no flaring (excluding the initial flowback period)

• (D) Number of completions or workovers that did not flare or vent gas (excluding the initial flowback period)

• (ii) Number of completions or workovers that did not employ a reduced emission completion (REC)

• (A) Number of completions or workovers that flared gas with no venting (excluding the initial flowback period)

• (B) Number of completions or workovers that both flared gas and vented gas (excluding the initial flowback period)

• (C) Number of completions or workovers that vented gas with no flaring (excluding the initial flowback period) (D) Number o f completions or workovers that did not flare or vent gas (excluding the initial flowback period) Response: In the final rule, the EPA is maintaining the requirement to measure emissions by different combinations of activities (horizontal or vertical, with or without flaring, and with or without reduced emission completion / workovers) as proposed . See Section II.B.5 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: V. Bruce Thompson Commenter Affil iation: American Exploration & Production Council (AXPC) Document Control Number: EPA

- HQ

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- A2 Comment Excerpt Number: 12

30Comment: AXPC and the Alliance request that EPA reconsider the splitting up of reporting and measurement categorie s for the liquids unloading, well completions and workovers, associated gas venting and flaring, flare stacks, and desiccant dehydrator source categories. Reporters have established data collection and management systems based on the existing well type and other categories established by the existing rule and the proposed revisions would either double or quadruple the number of required measurements or calculations, input data management, and reporting requirements. AXPC does not object to reporting the num ber of sources that have the given characteristics for the existing categories, but objects to the creation of additional categories for data collection and reporting. Response: In the final rule, the EPA is retaining the requirement s as proposed to repor t the emissions based on the applicable groupings for the different sources listed by the commenter. The disaggregation of the data by these groupings will inform verification and analysis of the data and the EPA does not expect that the new requirements will impose a significant additional burden on reporters

. See Section II.B.5 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Documen t Control Number: EPA

- HQ

- OAR

- 2011

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- 0087

- A2 Comment Excerpt Number: 4
Comment: A variety of analyses have utilized Subpart W data to help deepen understanding of emissions from the oil and gas sector, including the Annual Inventory of U.S. Greenhouse Gas Emissions and Sinks and efforts by academics and other researchers to assess emissions, which have provided essential independent information about emissions from this sector. 17 We specifically support many of the proposed revisions to Subpart W

— list ed below

— that would enhance the ability of the public and policy makers to use the data in future contexts like these.

• Gas well completions and workovers. EPA has proposed to revise the requirements for completions and workovers with hydraulic fracturing t o mandate the use of separate counts and separate emissions reporting for different well

- type combinations. 18 The separate well

type combinations are vertical or horizontal, with flaring or without, and utilizing a reduced emission completion/workover or n ot. These changes will result in more disaggregated data that will help distinguish emissions by well type and control technology. In addition to facilitating a better understanding of the factors affecting emissions, the proposed reporting requirements wi ll increase the value of the data for use in the Annual Inventory of U.S. Greenhouse Gas Emissions and Sinks. Footnotes:

17 See, e.g., David Allen et al., Measurements of methane emissions at natural gas production sites in the United States, 110 PNAS 17,7 68 (2013); A. R. Brandt et al., Methane Leaks from North American Natural Gas Systems, 343 SCI. 733 (2014).

3118 79 Fed. Reg. at 13,399

– 40. Response: The EPA thanks the commenter for their support

. In the final rule, EPA is maintaining the requirement to me asure emissions by different combinations of activities (horizontal or vertical, with or without flaring, and with or without reduced emission completion (or workovers)) as proposed . See Section II.B.5 of the preamble to the final rule for additional discu ssion responding to this comment. 

### 7.4 Comments on other minor revisions and restructuring of reporting requirements for gas well completions and workovers with hydraulic fracturing

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Instit ute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 56
Comment: Well venting during completions and workovers with hydraulic fracturing: Revisions to §98.233(g): EPA has replaced “backflow” with “flowback”.
API supports these changes. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: 98.236 (aa): Each facility must report the information specified in paragraphs (aa)(1) through (aa)(9) of this section, for each applicable industry segment, by using best available data. If a quantity required to be reported is zero, you must report zero as the value. (1) For onshore petroleum and natural gas production, report the data specified in paragraphs (aa)(1)(i) and (aa)(1)(ii) of this section. (i) Report the information specified in paragraphs (aa)(1)(i)(A) through (aa)(1)(i)(D) of this section for the basin as a whole. (A) The quantity of gas produced in the calendar year from wells, in thousand standard cubic feet. This includes gas that is routed to a pipeline, vented or flared, or used in f ield operations. This does not include gas injected back into reservoirs or shrinkage resulting from lease condensate production.

32The terms “vented” and “used in field operations” lack clarity and have not been described in any GHGRP or Subpart W documenta tion that API is aware of related to this requirement. API presumes that “used in field operations” means gas used on the well pad for fuel or pneumatic supply gas. The term “used in field operations” needs to be explicitly defined in the rule. API presume s that “vented” means gas vented by the source types requiring quantification and reporting under Subpart W. Where produced gas volume is currently quantified and reported, it is an estimated volume. Quantification of gas produced is not currently required in all jurisdictions and where it is required the State oil and gas regulatory authority often defines the specific scope of what is included and in some instances the methodologies for estimation. For purposes of Subpart W, the requirement to report the produced gas volume should be removed. Should EPA want to estimate this volume, EPA can add the volume of gas associated with emissions reported into the GHGRP to the sales gas volume at the facility (basin) level. Any expansion of the scope of items that need to be added to sales gas volumes to estimate produced gas volumes would require quantification of gas uses explicitly excluded from Subpart W quantification and reporting and would impose enormous burdens. Several examples that illustrate this problem follow:

• Venting during oil well flowbacks

• Volume of gas vented from equipment blowdowns

• Volume of gas combusted for process heaters < 5 mm Btu /hour For each of these a reporter would be required to put the systems and processes in place to gather data and in formation on which to base an estimate of gas use, calculate an estimate of the volume of gas use, and then add this volume to the sales gas volume and the volume of gas used that is estimated elsewhere in Subpart W. This significantly expands the scope of the rule to include sources explicitly excluded from the GHGRP or that are handled with counts of equipment such as externally fired heaters < 5 mmB tu /hr. API urges EPA to remove the requirement to report the volume of produced gas from the final rule. Resp onse: The EPA considers “vented” and “used in field operations” to be common terms that do not need to be further defined. The proposed rule language clearly requests a cumulative of all gas produced from the wells in a given basin and does not limit this value to vents or other releases that are specifically accounted for under subpart W. R eporting requirements by themselves do not obligate measurement systems to be installed. Through this response, EPA reinforces that position and confirms that using the best estimate s to determine the quantity of gas produce d from wells is adequate and allowed for this reporting requirement . The reporting requirements in §98.236(aa)(1)(i)(A) are being final ized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API)

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- A2 Comment Excerpt Number: 86
Comment: (B) The quantity of gas produced in the calendar year for sales, in thousand standard cubic feet. This requirement is fine as written. Response: The EPA thanks the commenter for their support. This revision i s finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 87
Comment: (C) The quantity of crude oil ratio, and best available estimate of produced in the calendar year for sales, not including lease condensates, in barrels. (D) The quantity of lease condensate produced in the calendar year for sales, in barrels.
For sub

- paragraphs (C) and (D), the term “lease condensate” has not been defined by the EPA under the GHGRP. There is a “condensate” definition in 98.238 but it is not specific enough to be applied to th is reporting requirement and not consistent with what operators commonly term “condensate”. In addition, operators typically track and account hydrocarbon liquids produced on a well/lease as one category “crude and condensate”. Operators would have signifi cant difficulty separating liquids production into crude oil and lease condensate. API recommends that §98.236(aa)(1)(i)(C) and (D) be collapsed into one reporting requirement as follows: (C) The quantity of crude oil and condensate produced in the calenda r year for sales, in barrels. With the revision suggested above, §98.236(aa)(1)(i)(D) should be eliminated. Response: These proposed reporting requirements were intended to support verification and analysis of the reported data. The EPA has determined tha t an aggregate total will serve th is purpose. Therefore, we are finalizing a reporting requirement for the quantity of crude oil and condensate in §98.236(aa)(1)(i)(C) and deleting the proposed paragraph §98.236(aa)(1)(i)(D) as suggested by the commenter

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 88
Comment: (ii) Report the information specified in paragraphs (aa)(1)(ii)(A) thro ugh (aa)(1)(ii)(M) of this section for each unique sub

- basin category. (A) State.

34(B) County. (C) Formation type. (D) The number of producing wells at the end of the calendar year. (E) The number of producing wells acquired during the calendar year. (F) Th e number of producing wells divested during the calendar year. (G) The number of wells completed during the calendar year. (H) The number of wells taken out of production during the calendar year. It is not clear to API what the information required in ite ms (ii) (A) thru (H) has to do with reporting of GHG emissions. It appears to API that EPA is attempting to construct a comprehensive count of wells in the U.S. with a great deal of specificity along with a comprehensive understanding of changes in the num ber of wells. API does not believe the GHGRP is the appropriate vehicle to gather this type of data. API also holds that the required information is not related to emissions reporting, and that requiring reporting of this information is an overreach of EPA ’s authority. API urges EPA to remove these reporting requirements from the final rule. Additionally, a well inventory parsed in the manner EPA is requiring is not information that an operator already tracks or has prepared. Requiring reporting of the information in items (ii) (A) thru (H) will impose a significant burden on reporters with no improvement or change in the quality of emissions data reported. API also notes that EPA has other avenues at its disposal to acquire the information

- such as the commercial data systems such as DI

- Desktop or the EIA’s information. From a practical standpoint, a number of the requested items need to be clarified:

• (D) A count of wells that are actively producing at the end of the year may not be representative of t he number of wells which contributed emissions to the annual estimate. For example, does this count exclude wells temporarily shut

- in or experiencing downtime? Does this only exclude wells that were plugged and abandoned?

• (E) Does this refer to wells that were acquired and are now under operational control of the reporter as of 12/31 of the reporting year?

• (F) Does this refer to wells that were divested and are no longer under operational control of the reporter as of 12/31 of the reporting year?

• (G) The nu mber of wells completed during the calendar year is reported elsewhere in the rule and redundant reporting here is not necessary.

• (H) Does this refer only to wells that were plugged and abandoned? What if they have been temporarily shut

- in or temporarily abandoned?

35Response: The EPA maintains the information listed by the commenters is needed to characterize and inform the EPA ’s verification of the data . We disagree with the commenters that the information would be overly burdensome to collect

. The EPA co nsiders the reporting requirements to be fairly self

- evident. We are clarifying in this response the answers to specific questions provided by the commenter. Well counts in (D) w ould include wells that are temporarily shut

- in or experiencing downtime, but should exclude wells that are plugged or abandoned. Wells acquired during the calendar year in (E) w ould include all wells acquired during the calendar year, regardless of whether the reporter maintains operational control of the well as of 12/31 of the re porting year. Wells divested during the calendar year in (F) would include all wells that were in operational control of the reporter at some point during the calendar year but that are no longer under operational control of the reporter as of 12/31 of the reporting year. The number of wells taken out of production in (H) would include all wells permanently taken out of service (i.e., wells that are p lugged and abandoned ) , but would not include wells that are temporarily shut

- in or experiencing downtime. Re garding the commenter ’ s issue on (G), the EPA notes that the other reporting requirements concerning the number of well completions are disaggregated by well type combination. Reporting the total number of completions here provides a verification check on the disaggregated reporting elements and provides useful information by which to characterize the sub

- basin activities together with other sub

- basin summary data. We made minor clarifications to paragraphs (D) and (H) commensurate with the above guidance; otherwise, we are finalizing these reporting requirements as proposed.



### 8.0 Gas Well Completions and Workovers Without Hydraulic Fracturing

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference: §98.236(h)(1)(iii), Proposed Rule Text: Total number of hours that gas vented directly to the atmosphere during backflow for all completions in the sub

- basin catego ry (the sum of all “Tp” for completions that vented to the atmosphere as used in Equation W

- 13B).
Comment: This reporting element refers to “backflow”, but gas wells without hydraulic fracturing do not have “backflow”. Response: The EPA agrees with the commenter. We have revised §98.236(h)(1)(iii) to clarify that the reporters must supply the total number of hours that gas vented directly to the atmosphere during venting for all completions in the sub

- basin category. This change harmonizes with the calcu lation requirements in §98.233(h).

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API)

36Document Control Number: EPA

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- A2 Comment Excerpt Number: 109
Comment: Proposed Citation Reference for Comp letions and Workovers without Hydraulic Fracturing:§98.236(h)(2)(iii), Proposed Rule Text: Total number of hours that gas vented to a flare during backflow for all completions in the sub

- basin category (the sum of all “Tp” for completions that vented to a flare from Equation W

- 13B).
Comment: This reporting element refers to “backflow”, but gas wells without hydraulic fracturing do not have backflow. Response: The EPA agrees with the commenter. We have revised §98.236(h)(2)(iii) to clarify that the reporter s must supply the total number of hours that gas vented directly to the atmosphere during venting for all completions in the sub

- basin category. This change harmonizes with the calculation requirements in §98.233(h).



### 9.0 Blowdown Vents
9.1 Revisions to Eq uations W
- 14A and W
- 14B to add a compressibility term (includes harmonizing changes to Eq uations W
- 33 and W
- 34)

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

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- A1 Comment Excerpt Number: 6
Comment: A revised calculation methodology for emissions from blowdown vents is proposed which will allow the use of a compressibility factor. Currently, emissions from blowdown vents are assumed to have a compressibility factor of one (1) which is not accurate at high pressures and low temperatures. The use of a blowdown specific compressibility factor will increase the accuracy of this estimate. We support these changes which will result in a more accurate emissions determination for these sources. Response: The EPA thanks the c ommenter for their support. The EPA has revised the proposed requirements in this final rule to allow reporters to use a site

- specific compressibility factor or use a default compressibility factor of 1 . See Se ction II.B.6 of the preamble to the final rule regarding changes to the calculation methodology for emissions from blowdown vents to allow the optional use of a compressibility factor.

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Comment Excerpt Number: 10

37Comment: The Use of Compressibility Factor Should Be Optional, Not Mandatory, in Blowdown Vent Emission Calculations. For blowdown vent stacks, Subpar t W currently contains emission calculations that do not use a compressibility factor. 14 In the Proposed Rule, EPA proposes to mandate the use of a compressibility factor (denoted Za) in such calculations. 15 EPA asserts that the change is not likely to increase reporting burdens, because EPA further proposes to include a default compressibility value of "1" for use in a set of circumstances that the Agency believes covers the most common measurements taken by pipeline operators. 16 Kinder Morgan strongly opposes the mandatory use of the compressibility factor for blowdown vent calculations because EPA’s proposed default compressibility factor of "1" would not be available for the most common measurements made b y pipeline operators. As proposed, EPA’s requirement to use a compressibility factor would impose a significant burden on industry without creating substantive benefits in terms of increased data and emissions accuracy. While some companies already use a c ompressibility term in their blowdown emission calculations, many do not. For companies not using compressibility factors in longstanding company processes, the addition of a compressibility term across hundreds of facilities encompassing thousands of blow down events would result in unnecessary costs and duplicative calculations within company records. In addition, the inclusion of a mandatory compressibility factor in blowdown emission calculations will result in inconsistencies with prior year reports tha t do not include a compressibility factor in the blowdown emission calculations. Despite the large burden this change would impose on operators, requiring use of a compressibility factor leads to no appreciable benefit in terms of improved data accuracy. A s INGAA’s comments note, the potential bias introduced by failure to use a compressibility factor is on the order of 10%

– small relative to other sources of uncertainty within required Subpart W estimation methods. Given the significant costs that the man datory use of a compressibility factor would place on the industry for only small improvements in data accuracy, the EPA’s compressibility factor proposal is not justified. For these reasons, Kinder Morgan strongly opposes the Agency’s proposal to require the use of a compressibility factor for calculation of emissions from pipeline and storage facilities. However, Kinder Morgan strongly supports allowing the optional use of a compressibility factor in blowdown vent emission calculations. For operators easi ly able to accommodate the use of a compressibility factor, this change would not impose new burdens, and would provide greater flexibility. Accordingly, Kinder Morgan requests that EPA modify its proposed Equations W

14A and W

- 14B, found in 98.233(i), as follows in Figure 5: Figure 5: Proposed Modifications to 40 C.F.R. § 98.233(i). Proposed 40 C.F.R. § 98.233(i). Blowdown vent stacks.

. . . (i) Calculate the total annual natural gas emissions from each unique physical volume that is blown down using eithe r Equation W

- 14A or W

- 14B of this section.

38(Eq. W

- 14A) Where:

. . . Za= Compressibility factor at actual conditions for natural gas. You may use either a default value of 1, or calculate the compressibility factor based on actual temperature and pressure c onditions

. 1 if the temperature is above −10 degrees Fahrenheit and pressure is below 5 atmospheres, or if the compressibility factor at the actual temperature and pressure is 0.98 or greater. (Eq. W

- 14B) Za= Compressibility factor at actual conditions for natural gas. You may use either a default value of 1, or calculate the compressibility factor based on actual temperature and pressure conditions

. 1 if the temperature is above −10 degrees Fahrenheit and pressure is below 5 atmospheres, or if the compress ibility factor at the actual temperature and pressure is 0.98 or greater. Kinder Morgan also requests harmonizing revisions to Equations W

- 33 and W

- 34 in § 98.233(t). Finally, if EPA retains the proposed mandatory use of a compressibility factor or allows optional use of a compressibility factor, EPA should revise the compressibility factor calculations to reflect the temperatures and pressures at which natural gas pipelines and gas plants operate, as indicated in INGAA’s comments.
Footnotes:

14 See 40 C.F. R. § 98.233(i) (Eq. W

- 14A).

15 Proposed Rule at 13400.

16 Id. Response: The EPA evaluated the commenter ’ s concerns and has subsequently revised the rule to allow reporters the option to use a default compressibility factor of 1 or a site

- specific factor i nstead o f being required to use a site

- specific factor for specific temperature and pressure ranges. See Section II.B.6 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 32

39Comment: Compressibility factor: INGAA supports the optional use of a compressibility factor f

or blowdown vent calculations. EPA proposed revisions mandate its use at typical system pressures and this decision is not supported or justified; mandatory use is not necessary
. Current Subpart W equations W

- 14A and W

- 14B estimate natural gas emissions fr om equipment blowdowns using the ideal gas law: n = PV/RT, where "n" is the molar amount of the gas and is proportional to volume. As gas pressure increases from atmospheric, gas behavior deviates from ideal due to intermolecular forces. A compressibility factor, "Z", is added to the ideal gas law equation to account for the intermolecular forces. Adding the compressibility factor to the ideal gas law changes the equation to n = PV/ZRT. The inverse compressibility factor, "1/Z", is the difference between th e moles (i.e., "n") or mass (i.e., n * molecular weight) of the gas (for a specific temperature, pressure and volume) calculated using the ideal gas law and the moles or mass of gas calculated (for the specific temperature, pressure and volume) using the i deal gas law including compressibility. The transmission segment is required to report blowdown emissions; underground storage does not have a requirement to report this source. INGAA requested including compressibility for transmission blowdown calculatio ns as an option . This request was made to accommodate current practices where many operators already conduct blowdown calculations and use a compressibility term. These equations and calculations are embedded within longstanding company processes, and not using the compressibility term would result in unnecessary costs and two separate calculations (and values) within company records. However, others have implemented Subpart W reporting without the compressibility factor and have developed associated system s for data gathering and reporting. In some cases, these companies changed their existing practice to accommodate Subpart W requirements. As discussed in Comment 11, EPA has not defined or consistently applied data quality objectives. However, based on bia ses and uncertainties evident in Subpart W and for other GHGRP subparts, differences introduced through optional use of compressibility is relatively immaterial in comparison to other uncertainties. In addition, reporting could indicate whether compressibi lity was used so that EPA could understand the reporting basis. Because EPA defines operating bounds for application of Z, the Proposed Rule mandates its use for typical transmission operations. A. The Proposed Rule mandates the use of Z at typical pressur es for pipeline applications. Rather than adding compressibility as an option as requested by INGAA, compressibility will be required for nearly all equipment blowdown calculations at T&S facilities. Proposed revisions to Subpart W would add Z to equations W

- 14A and W

- 14B and mandate that Z be determined for equipment blowdown emission calculations with pressures greater than or equal to 5 atmospheres (73.5 psia). This same mandate is included in equations W

- 33 and W

- 34 for converting volume from actual to standard conditions. For pressures less than 5 atmospheres (and temperatures greater than

- 10 ° F) or Z values greater than or equal to 0.98, a default Z value of 1 can be used. As acknowledged by EPA in its technical support memo, transmission pipelines typ ically operate in the range of about 500 to about 1,000 psig 14 15 ; thus, Z would likely be required for most, if not all, transmission segment blowdown emission calculations. It appears that EPA does not understand this outcome.

40B. Preamble and technical s upport memo discussion indicate confusion and a fundamental lack of understanding of natural gas systems. INGAA is concerned that EPA does not understand and appreciate the implications of the Proposed Rule changes. Discussions in the preamble and technica l support memo indicate confusion and a fundamental lack of understanding of natural gas systems. In the preamble EPA states: "Because it is likely that most facilities handle gas within the proposed compressibility factor default ranges, it is unlikely th at adding this compressibility factor term into the blowdown vent stack calculations will significantly increase the reporting burden." [79 FR 13400]
This statement is not correct for most blowdown events at transmission facilities and is contradicted by i nformation in the Proposed Rule TSD where EPA cites an API reference: "Natural gas transmission compressor station components and main line pressures are in the range of 500 to 1000 psi (34 to 68 atmospheres). See page 6

- 32, American Petroleum Institute (A ugust 2009), Compendium of Greenhouse Gas Emission Methodologies for the Oil and Natural Gas Industry ." Additional text from the TSD, which presents natural gas compressibility for a range of temperatures and pressures, indicates confusion or a lack of und erstanding of natural gas system operations: "The compressibility of methane at standard conditions is close to 1. However, the compressibility of methane at low temperatures and high pressures is significantly different, as illustrated in Table 3.1. The n atural gas processing and transmission compression segments covered by subpart W can operate systems at pressures higher than 25 atmospheres. 16 [See Docket Id. No EPA

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- A1 for Table 3.1. Compressibility of Natural Gas at Sample Temperat ures and Pressures.] Although the EPA had previously considered including the compressibility term (76 FR 56010, September 9, 2011), the EPA ultimately did not propose including the factor. The EPA concluded at that time that including a compressibility ad justment could create a degree of uncertainty among reporters when trying to compare their reported blowdown values on a volume basis. The EPA noted at that time that although the compressibility of pure light hydrocarbon substances is well known, the comp ressibility of hydrocarbon mixtures is less well known and the composition of natural gas throughout the segments covered by subpart W can be variable. At that time, we determined that ideal gas law calculations were adequate for reporting purposes under P art 98. The EPA notes that the circumstances surrounding this issue are now different, because the EPA is proposing the option [ Emphasis added ] of using site

- specific data for gas compositions, if available. Therefore, the original concern regarding the va riation in the composition of natural gas at subpart W facilities and its effect on compressibility would be addressed through data collection on actual gas composition. The EPA has determined that at high pressures and low

41temperatures, the accuracy of th e emission estimate would be improved if a compressibility factor were included in the calculation." There are a number of areas of misunderstanding or confusion in the above support text, including:

• T&S and processing are the primary segments that report blowdown emissions. EPA’s Table 3.1 lists compressibility factors for natural gas systems for temperatures well below typical blow down releases

– e.g.,
- 190 o F and

- 100 o F. Curiously, the table increases temperature in increments of 50 K (or 90 o F), but ski ps a temperature range more representative of the vented gas (e.g., 40 to 120F) associated with transmission operations

– i.e., the table jumps by 100 K from

- 10 o F to 170 o F and does not present information at typical temperatures. This oversight appears to indicate that EPA does not understand typical operations for the emission sources that would use these equations. Further, only one of the four pressures listed (40 atm / 588 psi) is indicative of the typical range representative of transmission operati ons.

• As noted in the cited text, EPA’s explanation includes reference to gas composition, "EPA is proposing the option of using site

- specific data for gas compositions." INGAA does not understand the explanation that follows, because default natural gas co mposition is still allowed for compressor station emission calculations. See Comment 26 for additional discussion on gas composition

– and INGAA’s support of revisions that clarify that T&S sources can use default natural gas composition or site data at th e operator’s discretion. INGAA hopes that EPA does not intend to somehow intertwine Proposed Rule revisions that allow optional use of gas composition based on site data with blowdown calculations. INGAA supports the optional choices for gas composition an d, correspondingly, supports the option of using gas compressibility (Z) in equations W

- 14A and W

- 14B, and equations W

- 33 and W

- 34. C. INGAA has advocated for the optional use of Z in blowdown emission calculations since the onset of the Subpart W rulemaki ng. In comments on the 2010 proposed rule [75 FR 18608], INGAA requested the optional use of existing company algorithms and programs, which may include the compressibility factor, to calculate and document blowdown emissions. This option was requested by INGAA so that longstanding facility blowdown emission systems and calculations did not have to be changed. The exclusion of Z required changes to some of these systems and calculations. Additional detail is available in previous INGAA comments, which are r eferenced in Comment 1.
Footnotes:

14 "Greenhouse Gas Reporting Rule: Technical Support for Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule," EPA

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15 " Compe ndium of Greenhouse Gas Emission Methodologies for the Oil and Natural Gas Industry ," Page 6

- 32. American Petroleum Institute (August 2009)

4216 " Compendium of Greenhouse Gas Emission Methodologies for the Oil and Natural Gas Industry," Natural gas transmiss ion compressor station components and main line pressures are in the range of 500 to 1000 psi (34 to 68 atmospheres). See page 6

- 32, American Petroleum Institute (August 2009).

17 Compressibility factors calculated using the California Natural Gas Associat ion (CNGA) method. "Gas Pipeline Hydraulics" by Shashi Menon and Pramila Menon. Response: The EPA evaluated the commenter ’ s concerns and has subsequently revised the rule to allow reporters the option to use a default compressibility factor or 1 or a site

- specific factor instead of being required to use a site

- specific factor for specific temperature and pressure ranges. See Section II.B.6 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 45
Comment: INGAA supports revisions to blowdown calculation equations that allow the optional us e of a compressibility factor. Previous INGAA comments requested the optional use of a gas compressibility factor for blowdown vent stack calculations in §98.233(i). EPA proposes adding the compressibility factor, "Z", to blowdown emissions calculations in Equations W

- 14A and W

- 14B. However, to provide flexibility and accommodate ex isting systems used for blowdown tracking, use of the compressibility factor should be optional to accommodate existing practices for some operators. Revisions should not prescribe new requirements for operators that employ the current Subpart W calculatio n method. The Proposed Rule mandates use of the compressibility factor for typical T&S operating pressures, and it appears that EPA does not understand this implication. INGAA does not support mandatory use of a gas compressibility factor. See Comment 15 f or additional details and discussion. Response: The EPA evaluated the commenter ’ s concerns and has subsequently revised the rule to allow reporters the option to use a default compressibility factor of 1 or a site

- specific factor instead of being requir ed to use a site

- specific factor for specific temperature and pressure ranges. See Section II.B.6 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 54

43Comment: Compressibility does not introduce significant bias at typical T&S facility operating conditions. Transmission pipelines typical ly operate in the range of about 500 to 1000 psi. Table 2 lists estimated compressibility factors for natural gas at temperature and pressure ranges more typical for transmission operations. The gas temperature exiting a compressor is typically higher than ambient due to the energy added to the gas during compression. Thus, the table considers "1/Z" factors for gas temperatures ranging up to 130 ° F. At these temperatures and the highest pressures (i.e., 900

– 1, 000 psig), 1/Z values are estimated to be abou t 1.1; at lower temperature and moderate pressures (i.e., prior to compression), 1/Z is also on the order of 1.1. Thus, for typical operations, the bias from using the ideal gas law would be about 10%. Higher bias (e.g., about 20%) could occur in some case s but is not typical for most events. [See Docket Id. No EPA

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- A1 for Table 2. Estimated Natural Gas Compressibility Factors (Z) for Range of Operating Pressures and Temperatures.] 17 To summarize, the operating temperatures and pressures for natural gas transmission compressor station blowdowns, including compressibility in blowdown calculations will typically change calculated emissions 10% or less relative to the ideal gas law; EPA has not explained what accuracy improvement is anticipated or how any reduced bias relates to data quality objectives. In the TSD, EPA states: "The EPA has determined that at high pressures and low temperatures, the accuracy of the emission estimate would be improved if a compressibility factor were i ncluded in the calculation." EPA has not explained how the "improved emission factor accuracy" associated with including Z relates to GHGRP data quality objectives or compares with other uncertainties or biases in the GHGRP. INGAA believes that potential b ias or uncertainty of about 10% or less for a single source type is small relative to other Subpart W and GHGRP emission estimation methods (e.g., emission factors for many estimates). Further, it is not evident that EPA has considered how this uncertainty impacts the overall blowdown vents emission estimate uncertainty and then justifies the incremental costs based on the perceived benefit. In addition to compressibility factor inclusion / exclusion, the blowdown vent emission estimate uncertainty includes contributions from uncertainties in:

• Physical volume estimate ("determined by engineering estimates based on best available data" [§98.233(i)(1)]);

• Actual temperature and pressure estimates ("For actual conditions, reporters must use average atmospheric c onditions or typical operating conditions" [§98.233]); and

• Inherent assumption in equations W

- 14A and W

- 14B that the gas temperature in the unique volume is the same at the beginning and end of each blowdown. It is anticipated that compressibility factor i nclusion / exclusion would have negligible impact on the overall emission estimate uncertainty for blowdown vent stacks.

44Response: The EPA evaluated the commenter ’ s concerns and has subsequently revised the rule to allow reporters the option to use a defa ult compressibility factor of 1 or a site

- specific factor instead of being required to use a site

- specific factor for specific temperature and pressure ranges. See Section II.B.6 of the preamble to the final rule for additional discussion responding to thi s comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: If the compressibility factor is mandatory ra ther than optional, then missing data provisions must apply. The proposed missing data provisions do not specifically include compressibility factor as a calculation input that may not be available if process data is not collected at the time of a blowdown event or cannot be estimated. If the compressibility factor is not optional, the Proposed Rule must be revised to ensure that missing data provisions apply. This could be accomplished by adding the compressibility factor to one of the currently proposed m issing data provisions or by clarifying that the compressibility factor is considered activity data that would be covered under broadly applicable provisions in §98.235(g). Response: The EPA has revised the final rule to allow reporters the option to use a default compressibility factor of 1 or a site

- specific factor instead of being required to use a site specific factor for specific temperature and pressure ranges. Consequently, the re is no need for missing data procedures for this data element . See Sect ion II.B.6 of the preamble to the final rule for additional discussion regarding the optional use of site

- specific compressibility factors

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 56
Comment: Mandating the compressibility factor in blowdown vent calculations will add implementation costs that have not been considered by EPA. Some companies have revised their blo wdown vent tracking and calculations systems to comply with current Subpart W requirements and would incur costs to undo those system

- wide changes. Optional use of Z would allow operators to use existing calculations and systems that are otherwise consiste nt with Subpart W and minimize Proposed Rule implementation costs. In the Proposed Rule Assessment of Impacts memo, EPA incorrectly concludes that the proposed rule change would have no impact on implementation costs:

45"The EPA is proposing to add a compres sibility term to the blowdown vent stack calculations. It is anticipated that reporters handle gas within the proposed compressibility factor default ranges; therefore, it is unlikely that adding this compressibility factor term into the blowdown vent stac k calculations would increase burden to reporters. Therefore, the EPA did not estimate the potential burden impact to reporters for this change." As demonstrated above, reporters typically handle gas over a broader pressure range than the proposed compressibility factor default pressure range, and mandating the use of the compressibility factor in blowdown vent calculations would require changes to existing systems and increase implementation costs. EPA has not considered or justified these costs, nor demonstrated that compressibility factor inclusion will significantly and cost

- effectively reduce the overall perceived uncertainty of the blowdown ven t emission estimates, especially when these uncertainties are considered within the context of other GHGRP sources. Many operators have developed and implemented blowdown tracking systems and calculation methods consistent with the Subpart W final rule (i. e., using the ideal gas law). Revising Subpart W to allow the optional use of the compressibility factors would allow operators to continue to use existing calculations and systems and would not significantly impact the reported emissions. Response: The E PA evaluated the commenter ’ s concerns and has subsequently revised the rule to allow reporters the option to use a default compressibility factor of 1 or a site

- specific factor instead of being required to use a site

- specific factor for specific temperatur e and pressure ranges. See Section II.B.6 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 73
Comment: GHG volumetric em issions using actual conditions, Revisions to §98.233(t): EPA is proposing to add a compressibility factors to the equations converting volumetric emissions in actual conditions to standard conditions. For Equation W

- 33, which converts natural gas emissions, reporters may use 1 if the temperature is above

- 10 degrees Fahrenheit and pressure is below 5 atmospheres, or if the compressibility factor at the actual temperature and pressur e is 0.98 or greater. For Equation W

- 34, which converts GHG emissions, reporters may use 1 if the compressibility factor at the actual temperature and pressure is 0.98 or greater. Comment: These revisions emphasizes the need for EPA to correct the emission equations for other source categories that are erroneously reported in “actual” gas conditions when the industry standard is to measure or estimate the gas volumes in standard conditions. The following equations are indicated in Subpart W to result in gas volumes in actual conditions:

• Volumetric CO2 emissions for acid gas removal units using calculation method 2 (Equation W

- 3). Here, the total annual volume of vent gas flowing out of the AGR unit in cubic feet per year is determined by flow meter. Flow met ers used in industry automatically compensate for

46compressibility based on pressure in correcting the gas volumes for the actual conditions and report the measured volumes in standard conditions.

• The volume of natural gas flowing into or out of an AGR unit for calculation method 3 (Equations W

- 4A and W

- 4B). Engineering calculation or a continuous flow meter is allowed for determining these volumes, where standard industry practice for either calculating or measuring these flows would be in standard conditio ns.

• The average flow rate in cubic feet per hour for all measured wells of the same tubing diameter group and pressure group combination in a sub

- basin, over the duration of the liquids unloading for calculation method 1 (Equation W

- 7A). Flow meters used b y industry correct the gas volumes for the actual conditions and report the measured volumes in standard conditions.

• Estimated venting emissions using Equation W

- 17A (for oil wells) or Equation W

- 17B for gas wells) for well testing venting and flaring. For oil wells, the GOR term used to estimate the gas volume is in units of standard cubic feet per barrel. For gas wells, the average annual production rate is determined for standard conditions.

• Estimated emissions from combustion units for onshore natural gas and petroleum production facilities (Equations W

- 39A and W

- 39B). The volume of gas to the combustion units used in these equations is determined or measured in standard conditions. For each of these equations, industry standard practice is to quantify the gas volumes at standard conditions. It makes no sense for a reporter to convert a gas volume from standard conditions to actual to comply with the designated outputs from these equations, and then reconvert to standard conditions to comply with the ref erences to 98.233(t) Equations W

- 33 and W

- 34. It appears EPA has added the compressibility term to Equations W

- 33 and W

- 34 to account for high gas pressure operations in the transmission sector. The compressibility for natural gas in transmission service ( high pressure gas composed primarily of CH4) will be very different than natural gas in production operations (lower pressure gas of variable composition). Even the technical support document posted to the docket for this proposed rule (Greenhouse Gas Repo rting Rule: Technical Support for Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule, February 20, 2014) confuses the compressibility of natural gas and methane (Table 3.1 is labeled as providing compressibili ty factors for natural gas while text introducing the table describes the compressibility of methane). For oil and gas production operations, the only emission source where computing gas volumes at actual conditions is legitimate is the choke flow calculat ion used in equation W

- 11A and W

- 11B. These are the only equations with application to the upstream oil and gas operations that should reference the conversion from actual to standard conditions in 98.233(t) and evaluate the need to correct for compressibi lity. API urges EPA to correct the emissions or gas volumes noted above to reference standard conditions. API intends to provide additional information demonstrating the minimal impact of compressibility based on typical pressures and temperatures in oil a nd natural gas production operations.

47Response: The EPA has revised the rule to allow reporters the option to use a default compressibility factor of 1 or a site

- specific factor instead of being required to use a site

- specific factor for specific temperat ure and pressure ranges. See Section II.B.6 of the preamble to the final rule for additional discussion regarding the optional use of site

- specific compressibility factors. Regarding revising Equations W

- 3. W

- 4A, W

- 4B, W

- 7A, W

- 17A, W

- 17B to reflect standar d conditions, we have made revisions to the introductory text in §98.233 and §98.236 to clarify that measurement systems that correct flows or volumes to standard conditions may be used directly in the above equations

. See Section II.B.13 of the preamble t o the final rule for additional discussion regarding the use of flow or volume measurement systems that correct to standard conditions.

Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Company (SoCal Gas) Document Contr ol Number: EPA

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- A2 Comment Excerpt Number: 11
Comment: SoCal Gas supports optional use of a compressibility factor. Requiring that compressibility be applied in the calculations will require a re

- working of existing systems which wi ll increase our burden and cost which was not accounted for in the impact assessment performed. Differences in calculated blowdown volumes introduced through optional use of compressibility are relatively immaterial in comparison to uncertainties in other calculation parameters. In addition, reporting could indicate whether compressibility was used so that EPA could understand the reporting basis. It is a longstanding practice for SoCal Gas to use a compressibility term in blowdown calculations for higher p ressure events (>100 psig). However, separate data gathering and reporting systems have been developed to implement Subpart W reporting without the compressibility factor to meet the existing requirements. Response: The EPA evaluated the commenter ’ s conce rns and has subsequently revised the rule to allow reporters the option to use a default compressibility factor of 1 or a site

- specific factor instead of being required to use a site

- specific factor for specific temperature and pressure ranges. See Section II.B.6 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerp t Number: 26

48Comment: Redundant recordkeeping requirement in Eq. W

- 14A and Eq. W

- 14B: EPA is proposing to modify these two equations by changing the description of “ N ” to “ Number of occurrences of blowdowns for each unique physical volume in the calendar year. You must retain logs documenting the number of occurrences of blowdowns for each unique physical volume in the calendar year .” This change should not be made for two reasons. First, including a recordkeeping requirement in an equation pa rameter description does not conform to typical rule writing practices. Additionally, 98.237(b) already requires, “ Results of all emissions detected and measurements .” 98.3(g)(2)(iv) already requires, “ Any facility operating data or process information use d for the GHG emission calculations .” Thus, this change is non

- conforming and redundant and should not be made. Response: The EPA agrees with the commenter that the recordkeeping requirements do not need to be specified in the equation variable descriptio n . EPA has removed the recordkeeping requirement from the description of the variable “N”

. As the commenter noted, t he recordkeeping requirements in § 98.3(g)(2) (iv) already require records to be kept for this parameter

.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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- A2 Comment Excerpt Number: 11
Comment: Williams believes the use of a compressibility factor other than 1 in Equations W

14A and W

- 14B should be optional. T his would allow current systems that utilize compressibility in their calculations to continue that practice. The proposed amendment places significant burden on the many reporters because compressibility factors would have to be determined for the vast ma jority of blowdowns, which involve starting pressures greater than 5 atm and temperatures greater than

- 10 degrees F. A compressibility factor equal to 1 provides a reasonably accurate, or sometimes slightly conservative, estimate of GHG blowdown emissions ; it is protective. Given the option, reporters will naturally be inclined to employ a compressibility factor less than 1 for cases where reported GHG emissions will be reduced most significantly. In summary, Williams believes mandatory use of a compressib ility factor results in added complexity with limited benefit. Response: The EPA evaluated the commenter ’ s concerns and has subsequently revised the rule to allow reporters the option to use a default compressibility factor of 1 or a site

- specific factor instead of being required to use a site

- specific factor for specific temperature and pressure ranges. See Section II.B.6 of the preamble to the final rule for additional discussion responding to this comment.

49

### 9.2 Revisions to require reporting of aggregated bl owdown emissions (in lieu of by "unique physical volume")

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Comment Excerpt Number: 12
Comment: Kinder Morgan Supports the Proposed Rule’s New Approach to Report Blowdown Emissions Reporting by "Equipment Type." Subpart W currently requires blowdown emissions to be reported by "unique physical volume" to EPA. Under § 98.236(c)(7), for each unique physical volume b etween isolation valves in a pipeline system greater than 50 cubic feet that is blown down more than once during the calendar year, the total number of blowdowns, annual emissions, and a unique identifier for the unique physical volume must be reported to EPA. For unique physical volumes blown down only once a year, less information must be reported: the total number of blowdowns, and an aggregate emissions figure for all such blowdowns. Under the Proposed Rule, EPA has proposed a different simplified appro ach: to require reporting of emissions from physical volumes greater than 50 cubic feet only on an aggregate basis according to "equipment type," with every physical volume falling into one of the following seven "equipment type" categories: station piping , pipeline venting, compressors, scrubbers/strainers, pig launchers and receivers, emergency shutdowns, and all other blowdowns greater than or equal to 50 cubic feet. 20 Kinder Morgan strongly supports this new approach to blowdown emissions reporting, whi ch provides more useful data to EPA and is less burdensome for reporting entities. To avoid confusion and any misinterpretation of the type of blowdowns, Kinder Morgan also recommends that the seven categories be called "equipment/event types" and be defin ed or explained in Subpart W or the preamble to the Final Rule. This label "equipment/event type" more accurately describes the "emergency shutdown" category. Additionally, EPA should clarify that emergency shutdown blowdown emissions should be categorized under the "emergency shutdown" category, regardless of the type of equipment that is blown down, and should further clarify the distinction between "station piping" (i.e., within the compressor station boundary) and "pipeline venting" (i.e., pipe external to the compressor station that is vented within the station boundary). Last, Kinder Morgan recommends that the category "all other blowdowns greater than or equal to 50 cubic feet" should be "all other equipment with a physical volume greater than or equa l to 50 cubic feet."
Footnotes :

20 Proposed Rule at 13431 (proposing new § 98.236(i)). Response: The EPA thanks the commenter for their support. The EPA agrees with the commenter that further clarification was needed on reporting blowdown emissions. In th e final

50rule, we have incorporated the term “equipment or event type ” to be consistent with emergency shutdown activities, revised the emergency shutdown category to include emergency shutdown blowdown emissions regardless of equipment type , and clarified the distinction between facility piping ( the te r m used in place of the proposed station piping ) and pipeline venting. We have also revis ed the category proposed as “all the other blowdowns greater than or equal to 50 cubic feet” category to "all other equi pment with a physical volume greater than or equal to 50 cubic feet" in order to clarify it is the physical volume of the equipment, not the blowdown volume (converted to standard conditions), to which the 50 cubic feet threshold applies

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 33
Comment: Tracking blowdowns by equipment type: INGAA supports categorizing an d reporting blowdowns by equipment / event type rather than by unique volume. However, some of the proposed revisions are unclear and revisions are needed. Proposed Rule revisions require categorizing and reporting blowdown emissions by equipment type acc ording to the following seven categories: station piping, pipeline venting, compressors, scrubbers/strainers, pig launchers and receivers, emergency shutdowns, and all other blowdowns greater than or equal to 50 cubic feet. INGAA recommended reporting by e quipment type rather than "unique volume" because this provides more pertinent data and is also more consistent with existing approaches for tracking blowdowns. However, rule revisions and clarifications are recommended:

• Six of the categories are equipment types; however, "emergency shutdowns" would be more accurately described as an event type or a reason for a blowdown, but the blowdown could also be associated with a listed equipment type. The rule should clearly indicate that emergency shutdowns would b e categorized under the "emergency shutdown" event category and not a related equipment category. This could be accomplished within the rule text or explanation in the preamble.

• Other than compressors, the categories of equipment types are not defined in t he rule or discussed in the preamble. Definition and/or discussion of these equipment types are recommended to clarify data collection and reporting requirements, and to promote consistency among reporters. For example, the difference between "station pipi ng" (i.e., within the compressor station boundary) and "pipeline venting" (i.e., pipe external to the compressor station that is vented within the station boundary) should be explained. Additional discussion and description is recommended to differentiate these two categories. Alternatively, these two types of blowdowns could be combined into one category called, "Piping

– Blowdowns and Purges".

• Similarly, the reporting obligation for compressors could be clarified by re

- labeling the "compressors" category as "Compressors

– Blowdowns and Purges."

51• The category "all other blowdowns greater than or equal to 50 cubic feet" should be "all other equipment with a physical volume greater than or equal to 50 cubic feet." Response: See the response to comment EPA

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- A1, Excerpt 12 in this section for the response to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Ex cerpt Number: 57
Comment: Operators are given the option of calculating emissions for each unique volume and tracking / reporting by equipment type per §98.233(i)(2) or by directly measuring blowdown vent emissions using a flow meter per §98.233(i)(3). F or section (i)(2) and related reporting, suggested revisions follow (added text in bold , deleted text in strike

- through) for rule text related to data collection and reporting: In §98.233(i)(2): "(2) Method for determining emissions from blowdown vent stacks according to equipment type. If you elect to determine emissions according to each equipment type, using unique physical volumes as calculated in paragraph (i)(1) of this section, you must cal culate emissions as specified in paragraphs (i)(2)(i) through (i)(2)(iii) of this section for each equipment type. Equipment or event (i.e., emergency shutdown) types must be grouped into the following seven categories: station piping, pipeline venting, co mpressors, scrubbers/strainers, pig launchers and receivers, emergency shutdowns, and all other blowdowns equipment with a physical volume greater than or equal to 50 cubic feet. If a blowdown event resulted in emissions from multiple equipment types and the emissions cannot be apportioned to the different equipment types, then categorize the blowdown event as the equipment type that represented the largest portion of the emissions for the blowdown event ." And, related reporting in §98.236(i)(1): "Report b y equipment type. If you calculated emissions from blowdown vent stacks by equipment types the seven categories listed in 98.233(i)(2) , then you must report the equipment types and the information specified in paragraphs (i)(1)(i) through (i)(1)(iii) of th is section for each equipment type. If a blowdown event resulted in emissions from multiple equipment types and the emissions cannot be apportioned to the different equipment types , then you must report the information in paragraphs (i)(1)(i) through (i)(1 )(iii) of this section for the equipment type that represented the largest portion of the emissions for the blowdown event." Response: The EPA has evaluated the commenter ’ s suggestion and agrees that it would clarify those situations where emissions canno t be apportioned to a specific equipment or event type. In the final rule , we have revised § 98.233(i)(2) to add: “ If a blowdown event resulted in emissions from multiple equipment types and the emissions cannot be apportioned to the different

52equipment ty pes, then categorize the blowdown event as the equipment type that represented the largest portion of the emissions for the blowdown event.”

Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

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- A2 Comment Excerpt Number: 5
Comment: A variety of analyses have utilized Subpart W data to help deepen understanding of emissions from the oil and gas sector, including the Annual Inventory of U.S. Greenhouse Gas Emissions and Sinks and efforts by academics and other researchers to assess emissions, which have provided essential independent information about emissions from this sector. 17 We specifically support many of the proposed revisions to Subpart W

— listed below

— that would enha nce the ability of the public and policy makers to use the data in future contexts like these.

• Blowdown vents. Similarly, the Agency has proposed to require reporting of blowdown emissions aggregated into seven categories: station piping, pipeline venting, compressors, scrubbers/strainers, pig launchers and receivers, emergency shutdowns, and all other blowdowns greater than or equal to 50 cubic feet. 19

17 See, e.g., David Allen et al., Measurements of methane emissions at natural gas production sites in th e United States, 110 PNAS 17,768 (2013); A. R. Brandt et al., Methane Leaks from North American Natural Gas Systems, 343 SCI. 733 (2014).

19 Fed. Reg. at 13,401. Response: The EPA thanks the commenter for their support. See Section II.B.6 of the preamble to the final rule for additional discussion regarding revisions made to the requirements for blowdown vent stacks

.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number:
Comment: Order of blowdown calculations is incorrect: EPA proposes that all unique blowdown volumes be summed into equipment types before applyin g gas compositions to determine CH 4 and CO 2 volumetric and mass emissions. This will lead to gross misapplication of gas composition to blowdown volumes in the gas processing sector. For example, most gas plants have compressors that compress inlet "wet ga s" and they have compressors that compress outlet "residue gas". These two gases have very different compositions. Yet, under the proposed methodology, all compressor blowdown volumes would be summed and then the reporter would somehow choose whether to ap ply the inlet gas composition or the outlet gas composition to this

53volume. In either case, the result will not represent actual emissions. This sort of gross and inaccurate presumption is highly illogical because elsewhere in this section, EPA is introduc ing extremely complex calculations to determine compressibility factors to presumably achieve a slightly higher degree of accuracy. Reporters are already determining the appropriate gas composition to use for each unique blowdown volume. We suggest that th is should remain the practice, and summation into equipment types should occur last (after application of 98.233(u) and (v)). Response: The EPA agrees with the commenter and has revised the final rule to incorporate the commenter ’ s suggestion for certain industry segments

. See Section II.B.6 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 59
Comment: For the transmission segment, INGAA recommends that all unique blowdown volumes be summed into equipment types before applying gas compositions to determine CH4 and CO2 volumetric and mass emissions. As discussed in Comment 23, INGAA recognizes that this approach may not be preferred for other segments where gas quality varies within the facility. Response: The EPA has retained the option to allow reporte r s in the onshore natural g as transmission compression and LNG import and export equipment industry segments to sum the blowdown volumes first, prior to applying gas compositions. We find that, for these industry segments, the blowdown gas composition will be similar across differen t events so there is no loss in accuracy if the volumes are summed fi r st. See Section II.B.6 of the preamble to the final rule for EPA’s response to this comment.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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- A2 Comment Excerpt Number: 3
Comment: Proposed EPA Amendment: Revise the current reporting requirements in 40 CFR 98.236(c)(7) to simplify the reporting structure to report blowdown emissions aggregated by seven categor ies: station piping, pipeline venting, compressors, scrubbers / strainers, pig launchers and receivers, emergency shutdowns, and all other blowdowns greater than or equal to 50 cubic feet. Williams supports the optional use of EPA’s seven proposed blowdown categories to help reporters identify and report types of blowdowns. We do not, however, support the mandatory

54use of the proposed categories, as this would force many reporters like Williams to redesign and modify electronic data acquisition and reportin g systems for facilities that are not staffed full

time. At Williams, many of these systems were designed and installed to comply with the unique

- volume reporting requirement of the current Greenhouse Gas Reporting Rule. Response: The EPA disagrees with the commenter ’s suggestion to make the blowdown categories optional. The EPA, as well as other commenters, have agreed that the requirement reduces burden and simplifies the rule. We also contend that providing the option to reporters would result in incon sistencies in the reported data such that the EPA would not be able to compare and review information between reporters. There are no changes to the final rule as a result of this comment. See Section II.B.6 of the preamble to the final rule for further di scussion regarding the blowdown categories. 

### 9.3 Optional calculation method where a flow meter is in use on a blow down vent
- proposed § 98.233(i)(3)

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 43
Comment: INGAA supports the addition of the method for determining blowdown vent emissions using a flowmeter. Minor revisions are needed to clarify method applicability and adjustments to measured emissions. Section 98.233(i)(3) is added to allow the installation of flowmeters on blowdown vent stacks to measure gas emissions rather than tracking individual blowdown events. This has the potential to reduce reporter burden in some cases. However, minor clarifications and adjustments are needed that include:

• The rule should clearly indicate that both the method for determining emissions from blowdown vent stacks using a flowmeter [§98.233(i)(3)] and the method for determining e missions from blowdown vent stacks according to equipment type [§98.233(i)(2)] can be used at facility for different blowdown emission sources. For example, if a facility vent includes a flowmeter, some but not all equipment vents may be routed to that ven t stack.

• When a flowmeter is used to report blowdowns, the reporting section implies that emissions are not tracked by equipment or event type and an annual total is reported. However, §98.233(i) does not clearly indicate this, and §98.233(i)(3) and/or (4) should be clarified to indicate that if the flowmeter option is used the emissions are not categorized and an annual total is reported.

• INGAA supports §98.233(i)(2)(iii) provisions, where the calculation to address gas composition uses the annual volume. However, INGAA recognizes that this approach may not be appropriate for upstream operations where gas quality may vary within the facility and separate calculations may be warranted. Thus, §98.233(i) revisions may be necessary to add flexibility and accomm odate various scenarios.

55Response: The EPA has evaluated the commenter ’ s suggestions and agrees that the changes would clarify the rule. In the final rule, the EPA is clarifying in §98.233(i) that the facility may use the equipment/event type method for s ome blowdown vent stacks and use the flow meter for other blowdown vent stacks. I f a reporter chooses to use a flow meter, they must measure the natural gas emissions from the blowdown(s) at the facility using a flow meter according to methods in §98.234(b ), and calculate annual CH4 and CO2 volumetric and mass emissions measured by the meters according to §98.233(i)(4). If the reporter chooses to use this method, they must also calculate an annual emissions total, and do not need to calculate emissions by t he seven categories listed in §98.233(i)(2)

. In the final rule, the EPA is clarifying in §98.236(i) that if both calculation methods are used, then the reporter must report by equipment/event type for the blowdown stack vents that use that method and repor t the total emissions for all blowdown vent stacks that use flow meters to determine blowdown emissions. 

### 9.4 Comments on other minor revisions and restructuring of reporting requirements for blowdown vents

Commenter Name: Jeff Applekamp Commenter Affiliation : Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number: 4
Comment: Assigning blowdown volumes to equipment: It is unclear what EPA’s intent is with the language in 98.236(i)(1) (shown below), but the following change must be made so that if reporters are able to delineate blowdown emissions within a "single event" to individual equipment types, they are allowed to do so. In many cases, equipment blowdowns are tracked by individual equipment and it may be more burdensome to lump blowdown emissions from one piece of equipment with another piece of equipment. 98.236(i)(1)...If a blowdown event resulted in emissions from multiple equipment types, then you must may report the information in paragraphs (i) (1)(i) through (i)(1)(iii) of this section for the equipment type that represented the largest portion of the emissions for the blowdown event. Response: The EPA agrees with the commenter that it is preferable to have the emissions apportioned by equipme nt type when possible

. We have revised the last sentence in § 98.236(i)(1) to state “If a blowdown event resulted in emissions from multiple equipment and the emissions cannot be apportioned to the different equipment, then you may report the information in paragraphs (i)(1)(i) through (i)(1)(iii) of this section for the equipment that represented the largest portion of the emissions for the blowdown event

. ” Similar language was added to § 98.233(i)(2) to clarify this in tent in the calculation methodology sec tion also.



### 10.0 Onshore Production Storage Tanks

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API)

56Document Control Number: EPA

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- A2 Comment Excerpt Number: 5
Comment: Onshore Production Storage Tank s: API supports EPA’s proposal to modify the requirements for onshore production storage tanks to eliminate the need for spatial data. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 6
Comment: API also generally supports revisions that provide an exception based approach for stuck dum p valves. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A 2 Comment Excerpt Number: 57
Comment: Onshore production storage tanks , Revisions to §98.233(j): EPA is proposing to modify the requirements for onshore production storage tanks to eliminate the need for spatial data collection. This revises the numberin g of the calculation methods. Comment: API supports the revisions to remove the reference to the location of the well head and separator or well head and tank. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 7

57Comment: API, however, disagrees with the revisions to Section 98.233(j) (6) which expands the universe of storage tanks subject to the rule. Specifically, the revised Section (j)(6) now includes storage tanks with throughput of less than 10 barrels per day which significantly expands the rule. While API appreciates that EPA ad opted the provision regarding exception reporting, as discussed infra, API objects to the expansion of reporting emissions from stuck dump valves to encompass all tanks. Response: The EPA thanks the commenter for alerting us to this issue

. T his was an ina dvertent error. We are clarifying in the final rule, both in § 98.233(j) and § 98.233(j)(6), that you must calculate emissions from dump valve leakage only if you use Calculation Method 1 or Calculation Method 2

. We are also revising the parameter “E n ” in Equation W

- 16 from the proposed rule to remove the reference to Calculation Method 3, which was erroneously included in the proposed rule. Additionally, we are revising the definition of the parameter “E n ” to include a reference to § 98.233(j)(4); this revi sion clarifies that the value of “E n ” used in Equation W

- 16 should exclude any recovered emissions. See Section II.B.7 of the pre amble to the final rule for further discussion related to this comment.



### 11.0 T ransmission Storage Tanks
11.1 Revisions to methods for qua ntifying emissions from the tank vapor vent stack

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: Transmission storage tank calculation requirements order: The order of requirements in 98.233(k) is confusing and should be changed to match the actual calculation progression. 98.233(k)(2)(iii) Use the appropriate gas composition in paragraph (u)(2)(iii) of this section.
98. 233(k)(2)(iv) Calculate CH4 and CO2 volumetric and mass emissions at standard conditions using calculations in paragraphs (t), (u), and (v) of this section, as applicable to the monitoring equipment used. 98.233(k)(3) If a leaking dump valve is... 98.233(k )(4) Calculate CH 4 and CO 2 volumetric and mass emissions at standard conditions using calculations in paragraphs (t), (u)(2)(iii), and (v) of this section, as applicable to the monitoring equipment used. 98.233(k)(5) 98.233(k)(4) Calculate the annual emis sion from storage tanks to flares... 98.236(k)(2)(iv) Annual... calculated according to § 98.233(k)(1) through (k)(4) (k)(3)

.

5898.236(k)(2)(v) Annual... calculated according to § 98.233(k)(1) through (k)(4) (k)(3)

. 98.236(k)(3)(iv) Annual... calculated according to § 98.233 (k)(5) (k)(4)

. 98.236(k)(3)(v) Annual... calculated according to § 98.233 (k)(5) (k)(4)

. 98.236(k)(3)(vi) Annual... calculated according to § 98.233 (k)(5) (k)(4)

. Response: The EPA agrees with the commenter that the calculations should be reorde red to match the calculation progression

. The EPA has revis ed these requirements as suggested by the commenter. These revisions separate out the measurement methods in § 98.233(k)(2)(i) and (ii) separately from the calculation requirements in proposed § 98.233(k)(2)(iii) and (iv) and remove any confusion regarding the order of calculations. 

### 11.2 Comments on other minor revisions and restructuring of reporting requirements for onshore transmission condensate storage tanks

Commenter Name: Jeff Applekamp Comment er Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number: 27
Comment: 29. Transmission storage tanks reporting: Several changes should be made for these reporting requirements:
98.236 (k)(1)(ii), (k)(2)(i), and (k)(3)(i) all contain language like "Method used to determine if dump valve leakage occurred." These requirements should be modified to include a specific list of options that EPA intends to program into e

- GGRT. Including this in the actual rule will avoid the confusion and changes that have occurred in the past when e

- GGRT programming added or "refined" reporting requirements. 98.236(k)(1)(iii) " Indicator Indicate whether scrubber dump valve leakage occurred for the transmission storage tank vent according to 98.233(k)(2) ." [Note: This clarification and reference needs to be made since the calculation section of the rule prescribes when "leakage occurred".] 98.236(k)(1)(iv) " Indicator Indicate if there is a flare attached to the t ransmission storage tank vent stack." Response: The EPA thanks the commenter for their suggestion. Given the number of methods available to reporters, it would be unwieldy to list each method in the reporting requirements in the final rule. The EPA will further consider these comments in the programming of future versions of e

- GGRT. The EPA has corrected the typographical errors in § 98.236(k)(1)(iii) and (iv) as suggested by the commenter.

59Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 35
Comment: §98.236 reporting requirements are substantially revised to better comport with analogous §98.233 emission estimation re quirements. In reviewing these revisions, some minor technical issues were identified:

• For each transmission storage tank vent, §98.236(k)(1)(iii) requires, "Indicator whether scrubber dump valve leakage occurred for the transmission storage tank vent." It is not clear what specifically is being requested by this item, and clarified text is required. Response: The first word should have been “indicate”

. The EPA has corrected this typographical error in §98.236(k)(1)(iii) and also in §98.236(k)(1)(iv)

.

Co mmenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number: 35
Comment: Leaking and venting time

– reporting requirements: Reporting element 98.236( q)(2)(iii) should be reworded to more accurately reflect reality. The component leaking time that is used in Equation W

- 30 is based on broad assumptions; the time is not based on actual field observations. For example, many operators will fix leaks that ar e detected during the survey, but they may not choose to perform an additional survey to "get credit" for those fixes. It would be inaccurate to characterize this time as "found leaking and operational". Transmission storage tanks have a similar issue. The following changes are suggested: 98.236(k)(2)(iii) Duration of time that venting is assumed to have occurred according to 98.233(k)(3) , in hours (may use best available data if a continuous flow measurement device was used). [see previous comment regardin g rearranging and renumbering certain of the 98.233(k) requirements] Response: The EPA agrees that the provisions of §98.236(k)(2)(iii) may be reworded to clarify that the time venting is an assumed leak time. We have revised §98.233(k)(2)(iii) as follows : "(iii) Duration of time that the leak is counted as having occurred, in hours, as determined in §98.233(k)(3) (may use best available data if a continuous flow measurement device was used)." These revisions are consistent with the calculation requirement s in §98.233.



### 12.0 Well Testing Venting and Flaring

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API)

60Document Control Number: EPA

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- A2 Comment Excerpt Number: 58
Comment: Well testing venting and flaring: Revisions to §98.233(l): EPA is proposing clarifying revisions to the text in this section. This includes modifying the definition of the term FR for equation W

- 17A from: “FR = Flow rate in barrels of oil per day for the oil well(s) being tested.” to “Average annual flow rate in barrels of oil per day for the oil well(s) being tested.” Comment: API is OK with these changes. However, the estimated venting emissions using Equation W

- 17A (for oil wells) or Equation W

- 17B (for gas wells) for well testi ng venting and flaring are indicated to result in gas volumes at actual conditions. For oil wells, the GOR term used to estimate the gas volume is in units of standard cubic feet per barrel. For gas wells, the average annual production rate is determined f or standard conditions. API requests that these equations be revised to utilize gas flow rates in standard conditions. Response: The EPA thanks the commenter for their support regarding the proposed changes to §98.233(1). Regarding revising Equation s 17

- A and 17

- B to standard conditions , we are finalizing revisions to the introductory text at § 98.233 and § 98.236 to clarify that use of systems that correct to standard conditions is allowed for these equations. See Section II.B.13 of the preamble to the fina l rule for additional discussion responding to this comment

.


### 13.0 Associated Gas Venting and Flaring

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 8
Comment: Associated Gas Venting and Flaring: API supports EPA’s proposal to add a term to Equation W

- 18 to account for when part of the associated gas from a gas well goes to a sales line while another part of the gas is flared or vented becaus e these amendments will eliminate erroneous over
- reporting. Response: The EPA thanks the commenter for their support. The term "SG p,q ”, which accounts for situations where part of the associated gas from a well goes to a sales line, has been retained in t he final rule. For additional edits to Equation W

- 18, see Section II.B.8 of the preamble to the final rule.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Co mment Excerpt Number: 59

61Comment: Associated gas venting and flaring. Revisions to §98.233(m): EPA is proposing to modify Equation W

- 18 to adjust the emissions downward based on the volume of associated gas sent to sales or emissions reported elsewhere ( such as when associated gas is flared or for gas emitted from tank flashing). EPA is defining a new term, ERE p,q as: Emissions reported elsewhere, volume of associated gas for well p in sub

- basin q, in standard cubic feet, during time periods in which asso ciated gas was vented or flared and for which emission source types of this section calculate and report emissions from the associated gas stream prior to venting or flaring of the associated gas (i.e., § 98.233(j) for onshore production storage tanks). API supports the addition of the SG p,q term to subtract gas sent to sales from the emission estimate. However, API does not support the addition of the ERE p,q term. We believe this will significantly increase the burden of tracking these “emissions reporte d elsewhere” with very little increase in accuracy. The equation terms are estimated by different methods (the volume of associated gas based on GOR, the volume of sales gas from a sales meters, and the volume of ERE by other estimation methods), so it is possible that the equation will result in negative volumes. API recommends removing the ERE p,q term from Equation W

- 18 and revising the definition of the summation term for the equation to indicate that it applies to associated gas not reported elsewhere. This is consistent with the new definition for associated gas venting and flaring which states “This does not include venting or flaring resulting from activities that are reported elsewhere, including tank venting, well completions, and well workovers.” T hese changes should minimize the potential for double counting emissions from associated gas reported elsewhere. Response: After considering the public comments, the EPA agrees that the potential for double

counting emissions using Equation W

- 18 with emissions reported elsewhere is minimal, particularly given the proposed definition of “associated gas venting or flaring.” Ther efore, we are finalizing Equation W

- 18 without an ERE term and we are finalizing the definition of “associated gas venting or flaring” as proposed. See Section II.B.8 of the pr eamble to the final rule for further discussion regarding this comment.

Commen ter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 121
Comment: Proposed Citation Reference for Associated Natural Gas Venting and Flaring: §98 .236(m)(7), Proposed Rule Text: Total volume of emissions reported elsewhere, in standard cubic feet, during time periods in which associated gas was vented or flared and which are calculated and reported under other paragraphs of this section, in standard cubic feet (the sum of “ERE p,q ” values used in Equation W

- 18 of this subpart). As indicated earlier, API recommends removing the ERE p,q term from Equation W

- 18.

62Response: As noted in our response to comment EPA

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- 18 without an ERE term. See Section II.B.8 of the preamble to the final rule for further discussion regarding this comment

.


### 14.0 Flare Stack Emissions

Commenter Name: Karin Ritter Commenter Affiliation: American Petrole um Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 61
Comment: Flare stack emissions: Revisions to §98.233(n): EPA is proposing to change mole percent to mole fraction where the gas composition is applied to estimate emissions from flares. EPA is also proposing to change the volumetric emissions from actual to standard conditions. API supports these revisions, especially changing the volumetric emissions from actual conditions to standard conditions. Response : The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Comment Excerpt Number: 16
Comment: Flare Stacks : To allow for the possibility of missing data in calculating flare stack emissions, Kinder Morgan requests that EPA make the following modifications to § 98.233(n) indicated in Figure 3: Figure 3: Proposed Modifications to 40 C.F.R. § 98.233(n). Proposed 40 C.F.R. § 98.233. Calculating GHG emissions. (n) Flare stack emissions. Calculate CO2, CH4, and N2O emissions from a flare stack as specified in paragraphs (n)(1) through (n)(9) of this section.

. . . (2) If you have a continuous gas composition analyzer on gas to the flare, you must use these compositions in calculating emissions. If you do not have a continuous gas composition analyzer on gas to the flare, you must use the appropriate gas compositions for each stream o f hydrocarbons going to the flare as specified in paragraphs (n)(2)(i) through (n)(2)(iii) of this

63section.

. . . (ii) For onshore natural gas processing, when the stream going to flare is natural gas, use the GHG mole fraction in feed natural gas for all streams upstream of the de

- methanizer or dew point control, and GHG mole fraction in facility specific residue gas to transmission pipeline systems for all emissions sources downstream of the de

- methanizer overhead or dew point control for onshore natural gas processing facilities. For onshore natural gas processing plants that solely fractionate a liquid stream, use the GHG mole fraction in feed natural gas liquid for all streams. If a measured gas composition is not available for the flare stack, use a re presentative composition for the stream as determined by engineering estimates, process knowledge, or best available data. (iii) For any applicable industry segment required to report flare stack emissions under §98.232 , when the stream going to the flare is a hydrocarbon product stream, such as methane, ethane, propane, butane, pentane

- plus and mixed light hydrocarbons, then you may use a representative composition from the source for the stream determined by engineering calculation based on process knowle dge and best available data.

. . . (5) Calculate GHG volumetric emissions from flaring at standard conditions using Equations W

19 and W

- 20 of this section.
Where:

. . . ZL= Fraction of the feed gas sent to a burning flare (equal to 1

- ZU). This fraction m ay be determined by engineering estimates, process knowledge, or best available data. Response: The missing data procedures are included in §98.235 in the final rule. For gas processing plants that do not have gas composition monitors, the reporters must determine the GHG mole fraction of the gas stream going to the flare based on whether the stream is from upstream or downstream of the de

- methanizer or dew point control. Given the amount of time available to take the measurement and the routine nature of the measurement, EPA does not agree that missing data provisions are necessary to add to paragraph (n)(2)(ii). The re are missing data procedures retained in §98.235 in the final rule for annual measurement data that allow reporters to repeat the estimation or measurement activity as soon as possible, including in the subsequent calendar year if missing data are not discovered until after December 31, until valid data for reporting are obtained. The EPA agrees with the commenter that the commenter’s suggeste d revisions to paragraph (n)(2)(iii) provide clarity and we have incorporated this change in the final rule. Regarding the additional language the commenter suggests for the definition of Z L , we note that this revision is unnecessary because Z L is defined as one minus Z U and the definition of Z U includes a provision allowing “engineering estimate and process knowledge based on best available data and operating records.”

64

### 15.0 Centrifugal and Reciprocating Compressors
15.1 Comments on proposed requirements for conducting volumetric emissions measurements for centrifugal or reciprocating compressors vented to common manifold or flare

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Numb er: EPA

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- A1 Comment Excerpt Number: 18
Comment: Proposed Rule revisions for measuring manifolded compressor sources are not adequately supported, and implemen t ation will not be safe or practical in some cases. It appears that EPA pr oposed rule revisions for measuring centrifugal and reciprocating compressor source emissions routed to a common vent manifold without review and analysis of available information. EPA has not defined the prevalence of manifolded systems that preclude indi vidual compressor source measurement, and has not included justification for these proposed revisions. EPA is in possession of e

- GGRT data and BAMM requests that could assist in defining the population of affected units. EPA has not adequately supported th e need to independently categorize this subset of compressor source measurements or to require more frequent (i.e., three times per year) measurements. EPA should justify why emissions estimated from reporter emission factors obtained from other existing m easurements do not provide a suitable and viable emissions estimate from compressors with manifolded vent lines. The Proposed Rule and EPA technical support document (TSD) 9 fail to address the following fundamental practical issues that may preclude measur ement from many manifolded compressor sources: unsafe to access and technically infeasible measurement locations; and vent gas from manifolded compressor sources that is comingled with gas from other emission sources. Previous industry comments and discuss ions, as well as numerous BAMM requests, have addressed the safety and technical feasibility issues with accessing and measuring certain vent lines. The discussion below explains how the Proposed Rule requirement to measure manifolded compressor source emi ssions at a single point in the manifold downstream of all compressor inputs and where emissions cannot be comingled with other non

- compressor emission sources retains the fundamental issue precluding measurement of individual compressor sources that are
m anifolded. All the manifolded compressors and other comingled sources would need to be shutdown, blown down, and purged, thus resulting in unnecessary GHG emissions, in order to safely install sample ports and re

- pipe vent lines (as needed to avoid comingl ing) to isolate emissions from the manifolded compressor sources. The Proposed Rule requires three measurements per year for manifolded compressor sources, taken before emissions are comingled with other non

- compressor emission sources. This requirement ap pears to be arbitrary and is not supported by data or conclusions drawn from 2011 or 2012 reported data or by defined data quality objectives. EPA has randomly concluded that three measurements per year are necessary to address "annual process variability" representative of an entire year. However, EPA has failed to demonstrate what additional insight may be

65obtained from three dissimilar measurements (e.g., compressor modes may or may not be the same from one test to the next) that could not be ascertained from a single measurement. The following two paragraphs from the TSD illustrate EPA opinions that are unsupported by credible data or basis for belief. These opinions have been used to establish a test frequency based on a perception that accuracy will be improved. Data quality and accuracy estimates are precluded by the inability to drawn meaningful conclusions from manifolded compressor source emissions measurements discussed further below). For example, EPA has failed to explain or expound on how manifo lded source

- mode emissions data are expected to be different from other compressor source emissions data and why three measurements are expected to reduce measurement uncertainty associated with dissimilar measurements. In addition, three measurements per year are not supported by a cost

- effectiveness determination as discussed below. Example text from the TSD or preamble follows.
"The EPA considered requiring only one or two measurements per year for these manifolded sources (as opposed to the EPA proposal above for the average of three measurements). The EPA concluded that the annual process variability for these sources was high enough to warrant more than one or two measurements per year ." [79 FR 13402] [ emphasis added ] "However, the process variation in a manifold fed by several sources over the year could be high enough that overall data quality could be reduced if one or two measurements are not representative of the entire year’s operations . The option to require three annual measurements from a single point in a manifold would likely reduce overall burden on reporters, while ensuring a more representative data set and better data quality than collecting one or two data points . Any of these options to require annual measurements would resolve the reporter’s concerns about the technical and safety issues with installing and utilizing sampling ports in manifolded lines. The accuracy of these options would vary with the number of annual measurem ents that would be required ." [ emphasis added ] Following this logic, one would conclude that using an emission factor developed from tens, hundreds, or thousands of measured data points would be more accurate, provide even greater data accuracy, be more re presentative, and reduce uncertainty and improve data quality. An emission factor approach (e.g., reporter emission factor) for manifolded sources reduces uncertainty and provides a viable emission estimation method that could be based on thousands of data measurements if developed from the entire data set of measurements completed to date. Adding 2013 and 2014 data, the uncertainty would be further reduced and the emissions estimate would be improved. So EPA is essentially requiring that the reporter devel op an "emission factor" based on three measurements of a conglomerated set of units operating in various modes accounting for various emission sources; yet, as discussed in comments on emission estimation alternatives, EPA ignores an approach that uses a s ource
- mode specific emission factor based on potentially hundreds of measurements. The lack of consistent logic relates to EPA’s failure to consistently apply reasonable data quality objectives, as discussed in Comment 11.
Footnotes :

669 "Greenhouse Gas Repo rting Rule: Technical Support for Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule," EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 19
Comment: Proposed Rule revisions would s ubstantially increase industry burden and EPA has inaccurately estimated costs. EPA has misrepresented the rule revision as a positive change beneficial to industry and a reduction in burden: "Reporters would no longer be required to annually measure compr essor sources that are manifolded individually. Instead, reporters would measure the manifolded group of compressor sources three times per year. Therefore, this proposed change is a burden reduction for reporters that have more than three compressor sourc es manifolded together." 10 "For example, if a reporter operates seven compressors that have their blowdown vent stacks manifolded, the reporter would no longer have to conduct seven measurements every year (one for each blowdown vent stack) as required by the current rule. Instead, for this example, the reporter would be required to only conduct a measurement three times per year on the common vent stack that is associated with the manifolded group of seven compressor sources, which would decrease burden fo r the reporter compared to the seven measurements currently required." [79 FR 13402] In concluding that the burden is lessened, EPA has failed to address the cost and potential logistical problems associated with mobilization of a test team two additional times per year (i.e., total of three times a year) to conduct measurements on manifolded compressor sources. Comment 9 provides additional discussion of actual costs associated with three separate annual measurements, and discusses logistical and schedulin g issues associated with third party crews that are often committed to other surveys (as opposed to mobilizing for a single measurement). In addition, there are logistical costs to mobilize operations personnel and coordinate with Gas Control to complete t hese additional measurements. Alternatively, costs would be incurred to acquire equipment and train staff at each site to conduct the two additional measurements. Further, EPA has not addressed the burden (possibly exorbitant if it is necessary to repipe e xisting systems to avoid co

- mingling) associated with installing sample ports on manifolded configurations. All compressors that are connected to the common manifold would be required to be shutdown, blown down (increasing GHGs), and purged in order to saf ely install sample ports

67and enable manifolded measurements unless the measurements could be safely conducted at the vent line exhaust. Further, the Proposed Rule requires that manifolded compressor source emissions must be measured "at a single point in t he manifold downstream of all compressor inputs and where emissions cannot be comingled with other non

- compressor emission sources." [§98.233(p)(4)(i)] Thus, for compressor sources with emissions comingled with other sources, a sample port would need to be installed prior to the comingling of gases from the compressor sources and the non

- compressor sources, and the manifolded compressors and other sources would need to be shutdown, blown down (increasing GHGs), and purged in order to safely install sample p orts and re

- plumb vent lines (as needed to avoid comingling) and enable manifolded measurements. Operational costs include manpower across multiple disciplines (e.g., operations coordination, selection of test port location, welders with hot work permits, etc.) and equipment to coordinate and execute port installation. Feasibility issues concerning both the technical issues and costs for re

- plumbing are not considered and could be significant problems. Adding the option to conduct measurements of manifolded compressor sources was intended to reduce burden by not requiring all compressors to be simultaneously shutdown to safely install sample ports on individual units. However, the requirement to conduct a measurement at a location where compressor source emi ssions cannot be comingled with other non

- compressor emission sources would in many cases require the shutdown of all associated equipment.
Footnotes :

10 "Assessment of Impacts of the 2014 Proposed Revisions to Subpart W ," EPA

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- 0063 (Februa ry 20, 2014). Response: The EPA appreciates the suggestions provided by the commenter and we have made revisions to the manifolded compressor measurement requirements as a result of comments received. W e are allowing a single annual measurement similar to other compressor sources

. In addition , we are revising the sampling requirement from the proposed rule so that the final rule reads as follows “Measure at a single point in the manifold downstream of all compressor inputs and, if practical, prior to comin gling with other non

- compressor emission sources”

. See Section II.B.11 of the pre amble to the final rule for further discussion regarding the final requirements for manifolded compressors

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Nat ural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 20
Comment: The manifolded compressor source measurement data will have limited utility (i.e., data that are not comparable to non

- mani folded compressor source data).
Treatment of other industries in the GHGRP is clear

– the objective is not to require measurement of every emission source and alternatives to measurement (e.g., emission factors,

68engineering estimates) are common for develo ping the facility inventory. Similar treatment should be afforded for T&S sources. For manifolded lines, other options, such as use of emission factors specific to the emission source and operating mode of interest, are available (i.e., reporter emission f actors). It is unclear what EPA expects to learn from measurements that will likely include different operating modes (i.e., different emission sources), because information on the individual compressor sources cannot be discerned. Numerous compressor mode

- source combinations are possible for each manifolded measurement, and measured emissions cannot be associated with an individual compressor source. That is, measurements from a common vent outlet cannot be used to characterize or understand annual emissio ns from individual compressors where multiple dissimilar vents (compressor source and mode) have been routed together. EPA has not provided data or analysis to compare or contrast manifolded compressor sources with non

- manifolded compressor sources. Furthe r, EPA has not explained how manifolded compressor source emissions data will be integrated in the inventory

– or will be used to address the GHGRP objective to inform future policy. Simplifying assumptions that apportion the emissions by unique compressor mode

- source combinations are likely to result in larger emissions uncertainties and fail to provide better data quality than emission factor approaches. The proposed rule requirements for manifolded measurements will provide dissimilar data that cannot be merged with existing 2011

– 2013 data and cannot be used to inform a heretofore undefined issue or concern that EPA has identified. Similarly, EPA has not supported its position for requiring measurements from all sources (refer to Comments 11 and 13). Th ese measurements will not provide meaningful information regarding compressor source emissions. Response: The EPA appreciates the concerns expressed by the commenter. The manifolded measurement alternatives were provided, in part, to address the technical and safety concerns for these sources that were raised during implementation of the rule . In this case, mea s urements are needed to characterize the emissions from the compressors. While credible and accurate emissions factors can provide a cost

- effective means of calculating GHG emissions for purposes of reporting under Part 98 , a t this time, the deferral of key data, such as reporter emission factors for the various compressor sources, limit s our ability to develop representative emission factors. See Section II.B.11 of the preamble to the final rule for further discussion regarding the final requirements for manifolded compressors

.

Commenter Name: Lisa Beal Commenter Affiliation: In terstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 21
Comment: Emissions from manifolded compressor sources that are comingled with other sources, unsafe to access, or techni cally infeasible to measure should be estimated using emission factors. Emission measurement requirements for measureable

- manifolded compressor sources should be limited to a single annual measurement.

69Manifolded compressor sources that are comingled with other sources, unsafe to access, or technically infeasible to measure should be exempt from emissions measurements, and their emissions can be estimated using emission factors. As discussed above, extraordinary effort to measure emissions from these source s is not warranted because the measurement data would have limited utility. Annual emissions measurements from measureable manifolded groups of compressor sources should be treated the same as non

- manifolded vent sources, and required to conduct a single a nnual emissions measurement. The same feasibility issues (safety, other access issues) that apply to single compressor vents also may apply to manifolded lines. EPA has not supported the need to differentiate this subset of emission sources nor provided a viable alternative to improve the emissions estimates from manifolded sources. As proposed, this alternative will not provide a greater understanding or meaningful insight into GHG emissions from manifolded compressor sources, as the sources will likely be measured in different modes and then averaged together. The resulting reported emissions from this alternative will provide a value for that measurement, but will not provide useful data or information to enhance the understanding of compressor sources. T he proposed requirement also does not address concerns regarding the burden and costs associated with three separate measurements, the installation of sample ports, or shutdown complications (i.e., shutting down all units at the same time) for port install ation. Should EPA disregard the above request to revise measurement requirements for manifolded compressor sources and retain tri

- annual measurement requirements, EPA should:

• Demonstrate that manifolded compressor source emissions data are necessary (e.g., identify data gaps and information voids in the absence of direct source measurements) through thoughtful consideration of existing reported data for these sources;

• Establish data quality objectives and define the purpose and end use of these measurements (i.e., explain how dissimilar data will be utilized and the expected outcome from these emission data);

• Support claims that three measurements will provide more insight on variability than one measurement per year and that three measurements support the a ssociated data quality objective;

• Discuss representativeness of manifolded compressor source measurements in different modes;

• Justify the cost and burden necessary to meet data objective(s);

• Provide an alternative for sources that are physically unable to safely access a location in the manifold downstream of all compressor streams and where emissions are not comingled with other non

- compressor emission sources. Response: The EPA considers measurement of manifolded compressors to be important. The EPA has revised the monitoring frequency to once per year for manifolded systems. See Section II.B.11 of the preamble to the final rule for further discussion regarding the final requirements for manifolded compressors

.

70Commenter Name: Lisa Beal Commenter Affil iation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 51
Comment: Manifolded Lines: EPA seeks comment on the Proposed Rule requirement to measure manifolded compressor sources emissions at least three times per year at a location where compressor source emissions cannot be comingled with other non

- compressor emission sou rces. As discussed in Comment 8, for measurement of manifolded compressor sources, EPA has not provided adequate technical justification for the proposed requirement for three measurements each year, and has greatly underestimated the costs associated with three separate measurement team mobilizations. Emission measurement requirements for measureable manifolded compressor sources should be limited to a single annual measurement. Manifolded lines where compressors sources are comingled with other emission s ources should rely on reporter emission factors developed for individual compressors. Response: The EPA has revised the monitoring frequency to once per year for manifolded systems. See Section II.B.11 of the preamble to the final rule for further discus sion regarding the final requirements for manifolded compressors

.

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

- HQ

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- A1 Comment Excerpt Number: 12
Comment: The issue of measuring manifolded compressor vent lines is addressed in the proposal by requiring at least three measurements of emissions from the common vent header over the year and reporting an average of these measurements. Since our company and many othe r companies conduct annual surveys using a contract service, this approach would be a logistical challenge to implement and likely more costly using contractors; the use of in

- house resources versus contractors may need to be evaluated if this part of the proposal is finalized. EPA has specifically requested comment on options for measuring emissions from manifolded compressor vent lines. Rather than this proposal, we request that company average emission factors be used for sampling points affected by mani folded vent lines. Currently in the e

- GGRT Subpart W data entry spreadsheet, the reporter indicates which compressor units have manifolded vent lines. We request that the Subpart W spreadsheet be further modified to prompt the reporter to enter a "Not meas ured" value for each affected sampling point. The rule currently requires that the reporter fill in company average emission factors for sampling points not measured during the reporting year in the "Not Measured" fields. Using company average emission fac tors for sampling points affected by manifolded vent lines would provide more accurate emission rate information than the current proposal of averaging three or more

71comb ined measurements. Combined (ma n i folded vent) measurements will not provide useful sam pling point information for specific operating modes. Response: The EPA has revised the monitoring frequency to once per year for manifolded systems. See Section II.B.11 of the preamble to the final rule for further discussion regarding the final requirem ents for manifolded compressors

.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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- A2 Comment Excerpt Number: 12
Comment: Williams does not support the requirement of three mea surements per year for commonly manifolded vents to atmosphere. Like many companies, Williams uses a third

- party contractor to conduct annual compressor monitoring as part of our greenhouse gas emissions inventory. The proposed amendment would create signi ficant logistical complications in scheduling the third

- party for return to facilities with manifolded compressor vents. The added margin of statistical accuracy and relevancy resulting from EPA’s proposed change would be very limited. For these reasons, W illiams believes annual as

- found measurements are of sufficient frequency for purposes of the GHG inventory. Also, as discussed previously, Williams objects to the collection of flow rate measurements in a manifolded flare header system for safety reasons. Response: The EPA has revised the monitoring frequency to once per year for manifolded systems. See Section II.B.11 of the preamble to the final rule for further discussion regarding the final requirements for manifolded compressors

.

Commenter Name: K arin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- 2011

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- A2 Comment Excerpt Number: 62
Comment: API supports the revisions to the emission estimation methods for centrifugal compressors that allow measurements at the manifold for compressors routed to manifolds. This provides added flexibility and addresses safety concerns. However, EPA should recognize that there may still be some manifolded compressors that do not currently have measure ment ports at a location where the compressor sources are not comingled with other sources, or where it is unsafe to access or technically infeasible to measure emissions. An emission factor approach is needed for these situations. In addition, annual emis sion measurements from measureable manifolded compressors should be treated the same as non

- manifolded emission sources and required to conduct a single annual emission measurement.

72Response: The EPA thanks the commenter for their support. While credible and accurate emissions factors can provide a cost

- effective means of calculating GHG emissions for purposes of reporting under Part 98 , the deferral of key data, such as reporter emission factors for the various compressor sources, limit s our ability to de velop representative emission factors. In response to this and similar comments, t he EPA has revised the monitoring frequency to once per year for manifolded systems. See Section II.B.11 of the preamble to the final rule for further discussion regarding th e final requirements for manifolded compressors

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

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- 2011

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- A2 Comment Excerpt Number: 68
Comment: API supports the revisi ons to the emission estimation methods for reciprocating compressors that allow measurements at the manifold for compressors routed to manifolds. This provides added flexibility and addresses safety concerns. However, EPA should recognize that there may st ill be some manifolded compressors that do not currently have measurement ports at a location where the compressor sources are not comingled with other sources, or where it is unsafe to access or technically infeasible to measure emissions. An emission fac tor approach is needed for these situations. In addition, annual emission measurements from measureable manifolded compressors should be treated the same as non

- manifolded emission sources and required to conduct a single annual emission measurement. Respo nse: The EPA thanks the commenter for their support. While credible and accurate emissions factors can provide a cost

- effective means of calculating GHG emissions for purposes of reporting under Part 98 , the deferral of key data, such as reporter emission factors for the various compressor sources, limit s our ability to develop representative emission factors. In response to this and similar comments, the EPA has revised the monitoring frequency to once per year for manifolded systems. See Section II.B.11 of the preamble to the final rule for further discussion regarding the final requirements for manifolded compressors

.

Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

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- 2011

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- 0087

- A2 Comment Excerpt Number: 6
Comment: A variety of analyses have utilized Subpart W data to help deepen understanding of emissions from the oil and gas sector, including the Annual Inventory of U.S. Greenhouse Gas Emissions and Sinks and efforts by academi cs and other researchers to assess emissions, which have provided essential independent information about emissions from this sector. 17 We specifically support many of the proposed revisions to Subpart W

— listed below

— that would enhance the ability of the public and policy makers to use the data in future contexts like these.

73• Centrifugal and reciprocating compressors. EPA also proposed to modify reporting requirements for centrifugal and reciprocating compressors routed to a common vent manifold. 20 Under the revisions, operators may take three aggregate measurements annually for all of the manifolded compressors. Direct measurements are important for this emissions source. At the same time, we respectfully urge the Agency to ensure that other key informat ion from each of the compressors in a common manifold is also reported, including information on the operating mode of each manifolded compressor at the time the measurement is made. 21
Footnotes:

17 See, e.g., David Allen et al., Measurements of methane em issions at natural gas production sites in the United States, 110 PNAS 17,768 (2013); A. R. Brandt et al., Methane Leaks from North American Natural Gas Systems, 343 SCI. 733 (2014).

20 Fed. Reg. at 13,402

– 03.

21 A simple aggregate of emissions from the ma nifolded compressors would provide potentially misleading information from these important emission sources, as all of the compressors might not be fully functioning at the time the measurement is made. Response: The EPA thanks the commenter for their sup port. The EPA has taken steps to ensure that key information from each of the compressors in a common manifold will be reported. T he final rule at § 98.236(o)(1) (iv) and (v) and § 98.236(p)(1) (v) through (vii) requires activity data, including mode informati on during the time of measurement, to be reported for each compressor whether the compressor is part of a manifolded group or not.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

- HQ

- O AR

- 2011

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- A3 Comment Excerpt Number: 14
Comment: 13. Manifolded vents with different compressor sources: GPA supports INGAA’s comments regarding the various issues associated with the proposed manifolded vent measurement requirements. Additionally, GPA notes that in many cases, different compressor sources may be manifolded together. For example, a rod packing vent can be piped to the blowdown vent. This situation does not appear to be fully contemplated in the proposed rule; rather, th e proposed rule only appears to contemplate the same compressor sources (i.e., rod packing vents) being manifolded together. EPA should not consider this type of configuration to be "co

- mingling." 14. Replace "8760" with "T" in Equations W

- 24B and W

- 29B : I f the entire manifolded group of compressor sources is not operating, reporters should be allowed to account for downtime. For example, if the manifolded group of compressor sources consists of reciprocating compressor rod packing sources (or centrifugal c ompressor wet seal oil degassing vent sources), and all of

74the compressors are not operating (such as when a gas plant is down), then these emissions should not be calculated during this downtime. Es,i,g = Tg * MT s, g,avg * GHGi,g Tg = Total time the manifolded group of compressor sources g had potential for emissions in the reporting year, in hours. Include all time during which at least one compressor source in the manifolded group of compressor sources g had potential for emissions . Default of 8760 hours may be used. Response: The EPA disagree s with the commenter that the proposed rule does not allow different compressor sources to be manifolded together. The rule at § 98.238 defines a manifolded group of compressor sources as “a c ollection of any combination of manifolded compressor sources (as defined in this section) that are manifolded to a common vent” [emphasis added]. However, the EPA agree s with the commenter that , if the entire manifolded group of compressor sources is not operating, reporters should be allowed to account for this downtime

. T herefore, the EPA has replaced "8760" with "T g " in Equations W

- 24B and W

- 29B. To provide greater clarity , the EPA has defined "T g " as “the total time the manifolded group of compressor s ources g had potential for emissions in the reporting year, in hours. Include all time during which at least one compressor source in the manifolded group of compressor sources g was in a mode

- source combination specified in either paragraph (o)(1)(i)(A), (o)(1)(i)(B), (p)(1)(i)(A), (p)(1)(i)(B), or (p)(1)(i)(C) of this section. Default of 8760 hours may be used.”

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number: 31
Comment: Unclear requirements regarding manifolded groups of compressors that contain centrifugal and reciprocating compressors: 98.233(o)(9) and 98.233(p)(9) both contain the language (analogous language for reciprocating com pressors), "If the centrifugal compressors included in the manifolded group of compressor sources share the manifold with reciprocating compressors, you must follow the procedures in either this paragraph (o)(9) or paragraph (p)(9) of this section to calcu late emissions from the manifolded group of compressor sources." Why is this sentence included here (for continuous monitoring method) but not in 98.233(o)(8) and 98.233(p)(8) (for as found measurements method)? It would appear that this sentence should be included in all of these sections or in none of them. Response: The EPA included this language to clarify that the calculation does not need to be repeated if centrifugal compressor sources are manifolded together with reciprocating compressor sources. W e agree that this clarification is applicable and necessary in § 98.233(o)(8) and (p)(8) and we are including this clarification in these paragraphs in the final rule.

75

### 15.2 Proposed definitions for "compressor mode", compressor source", "manifolded compressor so urce", and "manifolded group of compressor sources"

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

- HQ

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- 2011

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- 0073

- A1 Comment Excerpt Number: 4
Comment: Several definitions ar e proposed to be changed or added to provide needed clarity to the rule. The changes in definitions will clarify and provide consistency going forward in our understanding of these terms.

. . Revised definitions of "compressor", "compressor mode", and "man ifolded group of compressor sources" are proposed that clarify the meaning and provide further detail regarding the scope of these terms. We support these changes that provide needed clarity. Response: The EPA thanks the commenter for their support. The E PA is clarifying the definition of “compressor source” in this final rule to specify the applicability of the rule to specific compressor emission sources. See Section II.B.11 of the preamble to the final rule for additional discussion respon ding to this c omment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0081

- A1 Comment Excerpt Number: 40
Comment: The definition of "Compressor source" in §98.238 and referenced in §98.236(o) and (p) should be revised to improve clarity. Suggested revisions include: "Compressor source , for the purposes of Subpart W, means a specific type of compressor seal or valve . These include (wet seal s , blowdown valve s, and is olation valve s ) on a centrifugal compressor and blowdown valves, isolation valves, and rod packing on a reciprocating compressor ." Response: The EPA is clarifying the definition of “compressor source” in this final rule to specify the applicability of the rule to specific compressor emission sources. See Section II.B.11 of the preamble to the final rule for additional discussion respon ding to this comment.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document C ontrol Number: EPA

- HQ

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- 2011

- 0512

- 0084

- A2 Comment Excerpt Number: 36

76Comment: (§98.238) New definition for compressor source Compressor source means any type of vent or valve (i.e., wet seal, blowdown valve, isolation valve, or rod packing) on a centr ifugal or reciprocating compressor. The broad language in this proposed definition is not acceptable. It is not sufficiently clear to manage compliance and could lead to broad interpretation to sources not specifically called out in the rule. API requests that the definition for compressor source be revised to specifically list the required sources rather than include them in a parenthetical.

" For the purposes of Subpart W, compressor source means blowdown valve leakage through the blowdown vent, wet seal o il degassing vents, and unit isolation valve leakage through an open blowdown vent without blind flanges for centrifugal compressors. For reciprocating compressors, compressor source means blowdown vent leakage through the blowdown vent stack, rod packing emissions, and unit isolation valve leakage through the blowdown vent without blind flanges." Response: The EPA is clarifying the definition of “compressor source” in this final rule to specify the applicability of the rule to specific compressor emission sources similar to the clarification suggested by the commenter

. See Section II.B.11 of the preamble to the final rule for additional discussion responding to this comment

.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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- 2011

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- A3 Comment Excerpt Number: 15
Comment: New definition of "compressor source": EPA proposes a definition for the term "compressor source." GPA supports defining this term. However, as suggested by API, this definition must be changed to specifically indicate which compressor emission sources are covered by the rule. The proposed rule defines compressor sources as "any type of vent or valve (i.e., wet seal, blowdown valve, isolation valv e, or rod packing) on a centrifugal or reciprocating compressor." The phrase "any type of vent or valve" is too vague. See API’s comments for suggested language changes. Response: The EPA is clarifying the definition of “compressor source” in this final r ule to specify the applicability of the rule to specific compressor emission sources. See Section II.B.11 of the preamble to the final rule for additional discussion responding to this comment

.

Commenter Name: Karin Ritter Commenter Affiliation: Americ an Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

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- 0084

- A2 Comment Excerpt Number: 37

77Comment: (§98.238) New definition for manifolded compressor source Manifolded compressor source means a compressor source (as defined in this s ection) that is manifolded to a common vent that routes gas from multiple compressors. Comment: API supports this new definition and the flexibility it provides in allowing safer measurements at the manifold. Response: The EPA thanks the commenter for the ir support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- OAR

- 2011

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- 0084

- A2 Comment Excerpt Number: 38
Comment: §98.238) New definition for manifolded group of compressors Manifolded group of compressor sources means a collection of any combination of manifolded compressor sources (as defined in this section) that are manifolded to a common vent. API supports this n ew definition. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

- HQ

- OAR

- 2011

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- 0 084

- A2 Comment Excerpt Number: 44
Comment: Revisions to §98.232: EPA modified the source category for reciprocating engines in the list of sources to be reported for onshore petroleum and natural gas production facilities. 98.232(c)(11) Reciprocating com pressor rod packing venting. It appears EPA is making these revisions for consistency with the definition of compressor source under §98.238 and requirements for reciprocating compressors under §98.233(p), which apply to blowdown valve leakage, isolation v alve leakage, and rod packing leakage. API supports the removal of “rod packing” from the source category name for reciprocating compressor venting contingent upon EPA adopting the proposed definition of compressor source under §98.238. The proposed defini tion of compressor source is needed with this revision to prevent an expanded interpretation of emissions reporting for reciprocating compressors. Response: The commenter is correct that the proposed revisions are intended to harmonize with revisions to t he definit i on of “ compressor source ”

. The EPA is adopting revisions to the definition of “ compre ssor source ” in this final rule. S ee Section II.B.11 of the preamble to the final rule for additional information.

78

### 15.3 Revisions to calculation and reporting of emi ssions for compressors routed to a flare

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

- HQ

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- 2011

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- 0089

- A3 Comment Excerpt Number: 24
Comment: Misleading statement regarding compressors routed to flare
. 98.233(o)(12)(i) is circular in that is contains calculation requirements, but it also says that the calculation requirements of 98.233(o) do not apply. Additionally, it would be clearer to replace "emission calculations" with "requirements" since many of the paragraphs in (o) include emission calculations and measurement requirements. Analogous changes are suggested for section 98.233(p) as well. The following revision is suggested: 98.233(o)(12)(i) Emissions calculations under this paragraph (o) Paragraphs (o)(1) through (o)(11) of this section are not required for compressor sources that are routed to a flare. 98.233(p)(12)(i) Emissions calculations under this paragraph (p) Paragraphs (p)(1) through (p)(11) of this section ar e not required for compressor sources that are routed to a flare. Response: The EPA agrees with the commenter’s suggested edits and has incorporated these revisions into the final rule

.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partn ers, LP Document Control Number: EPA

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- 2011

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- 0091

- A2 Comment Excerpt Number: 10
Comment: While Williams agrees that compressor emissions routed to an operation flare should be reported under the flare source category, we object to the requireme nt that flow rates (part of the specified activity data) be collected for compressors routed to flare. Collecting discrete flowrate measurements in a closed piping system routed to a flare is potentially dangerous. A leak monitoring contractor for Williams reported instances at non

Williams facilities where they observed air entering the closed flare header system during compressor monitoring events. This could create an explosive environment within the flare header system. A second concern is potentially e xposing workers to hydrogen sulfide. Installing continuous flow meters on a closed piping system routed to flare for the purposes of compressor GHG monitoring would be very burdensome and disruptive to plant operations. Williams proposes the following alternative, consistent with calculation methods employed for other emission sources routed to flare. Allow reporters to use best engineering estimates and process knowledge when calculating and reporting compressor emissions routed to flare. The

79company
- w ide emission factors developed for the various compressor mode

– source combinations, along with compressor run times, could be effectively used to develop these engineering estimates. Response: The EPA has evaluated the commenter’s concerns and has determined the final rule does not need to be revised. The final rule at § 98.233(o)(12)(ii) and (p)(12)(ii) specifies that “if any compressor sources are routed to a flare, calculate the emissions for the flare stack according to paragraph (n) of this sect ion and report emissions from the flare according to §98.236(n), without subtracting emissions attributable to compressor sources from the flare.” The flare provisions at § 98.233(n)(1) allow a reporter to use engineering calculations based on best availabl e data or company records to estimate the flow to the flare that is not continuously measured. No change has been made to the final rule as a result of this comment.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- 2011

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- 0084

- A2 Comment Excerpt Number: 69
Comment: API supports the revisions that permit calculating and reporting compressor flare emissions with other flared sources, and that provide the flexibility to continu ously measure emissions. API supports the proposed change to calculate and reporting emissions from compressors routed to flares to be reported with other flare emissions. API request that EPA consider including the same provision for other emissions sourc es that are routed to a flare, such as dehydrator vents. Because the language included at §98.233(p)(12)(ii) was not included for these sources, emissions attributed to vent streams from these sources that are routed to a flare are still required to be sub tracted from the flare emissions and reported under the specific source of the vent stream per §98.233(n)(9). Response: The EPA thanks the commenter for their support. We did not propose to change the calculation procedures for these other sources to cons ider only cumulative emissions from flare stacks ; therefore, we conclude that the additional revisions suggested by the comment er are beyond the scope of this rulemaking. However, the EPA may consider the commenter’s suggestions in a future rulemaking. 

### 15.4 Re visions to 3
- year cycle requirement, schedule to measure compressors in the not
- operating
- depressurized mode, & schedule to measure compressors in the operating mode

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) D ocument Control Number: EPA

- HQ

- OAR

- 2011

- 0512

- 0089

- A3 Comment Excerpt Number: 5

80Comment: Compressor testing is inordinately expensive: For example, one GPA member company operates 28 compressors at four natural gas processing plants subject to reporting under subpart W of the Mandatory Greenhouse Gas Reporting Rule (GHG MRR, 40 CFR part 98). S ince they have only a few facilities subject to subpart W, they have opted to outsource their GHG compressor monitoring to a third party contractor who specializes in this type of work. Their decision to outsource monitoring was based on cost, data quality , and consistency of approach. After two years of monitoring, they have robust data on the actual cost of compressor monitoring In their experience, minimizing the number of mobilizations is key to minimizing third party monitoring costs. There are a coupl e of ways the contractor can minimize mobilizations. First, the contractor can multitask by conducting infrared camera leak monitoring and compressor monitoring during the same site visit. Second, the contractor can arrange to visit several facilities in t he same geographic area during a single trip. With these cost saving measures implemented, their actual 2013 compressor monitoring costs came to $4,176 per facility or $597 per compressor. The downside to this approach is that compressor monitoring cannot be scheduled around facility or compressor shutdowns. Instead, compressors are monitored "as found", and they are usually found to be operating. After two years of monitoring they have only managed to collect "not operating depressurized" (NOD) mode date f or 12 of 28 compressors [43 percent (%)]. Since this is their third year of monitoring, the remaining 16 compressors are required to be monitored in the NOD mode in 2014. These 16 compressors seldom operate in the NOD mode (21% of the time on average in 20 13). Some are in the NOD mode for only 3 or 4 days all year. Further, they rarely have multiple compressors at a single facility operating in the NOD mode simultaneously. To monitor these 16 compressors in the NOD mode in 2014 will require multiple mobiliz ations to each facility, and these monitoring events will need to be tightly scheduled around planned maintenance shutdowns. The cost and logistics of scheduling will be formidable challenges. 2014 NOD monitoring requirements will add $4,544 per facility ( $1,136 per compressor) to their 2014 compressor monitoring cost. Based on monitoring data collected to date, they know that NOD mode compressor emissions are minimal. The total methane (CH 4 ) emissions from all 28 compressors in the NOD mode in 2013 was 0.8 metric tonnes (mt) (20.2 mt carbon dioxide equivalent [CO 2 e]), as reported in their calendar year 2013 GHG emission inventories in EPA's electronic Greenhouse Gas Reporting Tool (e

- GGRT). (The CO 2 emissions are less than 0.5% of the CH 4 emissions on a CO 2 e basis so are not considered in this analysis). This company’s experience shows that the rule’s strict requirement to conduct NOD mode monitoring is leading to absurd results, where a contractor is having to drive hundreds of miles to mobilize to their fa cilities several times over the course of the year, burning fuel and producing CO 2 in the process, in order to collect 16 NOD measurements. Their experience also shows that the monitoring requirement is not cost effective. On a per ton basis, their costs t o conduct 2014 NOD mode compressor monitoring will exceed the typical cost to control criteria pollutants using best available control technology (BACT). For example, the total additional cost to conduct NOD monitoring in 2014 is $18,174 (for four faciliti es) while the

81total reported NOD emissions for all compressors in 2013 was 0.8 mt CH 4 . This translates to a monitoring cost of $22,492.57 per mt of CH 4 emitted. Monitoring compressors "as found": While GPA continues to assert that compressor testing shoul d not be required, while testing is still required, GPA supports INGAA’s comments regarding compressor measurements and that they should be completed "as found" without mandating mode

- specific measurements. As shown above, coordinating measurement efforts with compressor operations is extremely challenging. EPA has not provided evidence that data gaps exist to justify a mode

- specific measurement requirement. Additionally, EPA has not provided an assessment of how this data element impacts the overall GHGRP inventory data accuracy, and whether mode

- specific measurements result in data quality improvements that justify the additional burden. Response: In an effort to reduce the burden associated with measuring compressors in the NOD mode, w e are augmenting th e three

- year measurement requirement , as proposed with minor revisions , to specify that reporters must take a measurement in the NOD mode at least once in any three consecutive calendar years, provided the measurement can be taken during a scheduled shutdo wn. If three consecutive calendar years occur without measuring the compressor in NOD mode, you must measure the compressor at the next scheduled depressurized shutdown. With respect to the commenter’s assertion of the minimal nature of NOD mode emissions, the data available to us suggests that these emissions are not always as small as those indicated by the commenter and, for some industry segments, NOD mode emissions contribute significantly to the total annual emissions from compressors . As more data be come available to estimate NOD mode emissions, including data that are inputs to emissions equations that have been deferred until 2015, the EPA may consider further revisions to the NOD mode measurement requirements in a future rulemaking

. See Section II. B.11 of the preamble for additional discussion regarding the final requirements for compressor mode measurements

.

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

- HQ

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- 00 77

- A1 Comment Excerpt Number: 7
Comment: For Compressor Venting Measurements, Subpart W Should Rely Exclusively on the Annual "As

- Found" Measurement, Rather than Mandating Mode

- Specific Measurements at Specific Intervals. Subpart W currently requires rep orting entities to collect GHG emission data from each compressor vent on an annual basis "in the operating mode in which it is found" (referred to herein as "as

- found" mode). This provision further requires the reporting entity to specify whether the as

- f ound mode was: (i) operating; (ii) standby pressurized; or (iii) not

- operating, depressurized. 8 Subpart W also currently requires testing in the not operating, depressurized mode at least once every three consecutive calendar years.

82The Proposed Rule would retain both the annual as

- found requirement and the three

- year testing requirement for not

- operating, depressurized compressors. Further, it would add another mandated, mode

- specific testing requirement: a requirement to test the emissions of centrifugal compressors in the operating mode once in any three consecutive years; if the centrifugal compressor is not measured in the operating mode at least once in any three consecutive years, it must be measured in the operating mode in the next calendar year tha t the compressor operation exceeds 2,000 hours. 9 Data already submitted to EPA demonstrate that the annual compressor testing requirement

– without consideration of data submitted only as a result of the three

- year compressor not

operating, depressurized t esting requirement

– has yielded extensive data on compressor emissions, including in each of the three operating modes . As explained in the INGAA comments, the first two years of Subpart W reporting have generated more than a thousand reciprocating compre ssor measurements for each of the three operating modes, and hundreds of centrifugal compressor measurements for each of the operating modes. Because the annual as

found measurements already generate such extensive data on emissions in all three modes, fur ther mode

- and time

- specific testing does not result in meaningful additional emissions data beyond what is already being collected in the as

- found mode. Not only does the Proposed Rule fail to justify the need for further mode

- and time

- specific testing r equirements, it also fails sufficiently to justify the unreasonable added costs and complexity imposed by these requirements. In addition to the already substantial costs and complexity of the annual compressor measurements, the existing three

- year require ment creates cumbersome scheduling and logistical issues for measurement personnel. Because of EPA’s three

- year requirement, Subpart W measurement teams are required to schedule costly “out

- of

sequence” tests that significantly raise the cost of annual mea surements. 10 The Proposed Rule is flawed because it fails to provide sufficient justification to continue to require not operating, depressurized mode measurements every three years. Elimination of this continued requirement would result in significant cos t savings to pipeline operators.
Footnotes :

8 Section 98.233(o)(1) provides that centrifugal compressors have two modes: operating and not operating, depressurized, and § 98.233(p)(1) provides that reciprocating compressors additionally have a third mode: standby pressurized mode.

9 Proposed § 98.233(o)(1)(i)(D).

10 INGAA’s comments note that compressor measurement costs its members between $3,000 and $6,000 per year per compressor, without consideration of scheduling, coordination, and other logistical and administrative costs, and without consideration of out

- of

- se quence costs. Response: We are not finalizing the requirement to measure in each mode at least once every three years although we are retaining, with minor revisions, the requirement to test in NOD mode at least once in any three consecutive calendar years, provided the measurement can be taken during a scheduled shutdown. If three consecutive calendar years occur without measuring the compressor in NOD mode, you must measure the compressor at the next sc heduled

83depressurized shutdown. As more data become available to estimate NOD mode emissions, including data that are inputs to emissions equations that have been deferred until 2015, the EPA may consider further revisions to the NOD mode measurement requi rements in a future rulemaking

. See Section II.B.11 of the preamble for additional discussion regarding the final requirements for compressor mode measurements

.

Commenter Name: Ritu Talwar Commenter Affiliation: Spectra Energy Corp Document Control Num ber: EPA

- HQ

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- A1 Comment Excerpt Number: 2
Comment: Compressor Test Should be Completed in "As

- Found" Mode Without Condition : Without reasonable justification, EPA proposes to mandate compressor measurements be made in specific modes an d at specified intervals without consideration for the increased costs and operational burdens this mandate imposes. Spectra Energy has collected compressor data in all three modes, operating, standby pressurized, and not

- operating depressurized and is abl e to generate reporter emissions factors for all modes. This proposed requirement presents operational scheduling challenges, increased cost burdens, both made unnecessary by the availability of data across all modes of operation. For these reasons, it is not necessary to mandate testing in any particular mode. Instead of adopting this prescriptive mandate, EPA should allow our industry to measure the equipment in the "As

Found" mode without condition. Response: See response to comment EPA

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- A1, Excerpt 7 and Section II.B.11 of the preamble for additional discussion regarding the final requirements for compressor mode measurements

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Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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- A2 Comment Excerpt Number: 14
Comment: Proposed EPA Amendment: If there is no scheduled shutdown within three consecutive years, a measurement must be made at the next scheduled depressurized compressor shutdown.
With this amend ment, it appears that EPA is attempting to alleviate the forced shutdown scenario. While at some facilities, like gas processing plants, it may achieve this purpose. At others locations where facility shutdowns are uncommon (e.g. compressor stations), oper ators would likely force unit shutdowns while the measurement contractor is on site. This would result in the unintended consequence of emitting additional greenhouse gases solely for the purpose of

84obtaining a measurement. Ultimately, Williams believes an nual as

- found monitoring conducted company
- wide generates sufficient data for the various compressor mode

– source combinations. Response: See response to comment EPA

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Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Comment Excerpt Number: 8
Comm ent: Moreover, with respect to the Agency’s proposal to require additional testing in the operating mode every three years, EPA has not properly estimated the incremental time and cost that operators will incur to comply with the requirement. Contrary to EPA’s assumption that the incremental time and costs to collect additional measurements would be unchanged, the imposition of this additional three

- year mode specific requirement will require additional expense to mobilize highly trained measurement teams for yet more out

- of

- sequence testing. 11
The costs of the three

- year requirement are not only economic, however; there are also environmental impacts. Even though "EPA did not intend for reporters to perform an unscheduled shutdown of a facility for the sol e purpose of taking a measurement of the compressor in the not

- operating

- depressurized

- mode," 12 the three

- year requirement has already led to unnecessary vented emissions due to shutdown mode tests undertaken by operators solely to comply with Subpart W’s three

- year measurement requirement. For these reasons, Kinder Morgan urges EPA to eliminate all compressor testing requirements other than the annual, as

- found requirement. Companies would still be required to report the specific operating mode during whic h measurements were conducted, and EPA would still receive substantially the same amount of data from Subpart W reporting entities.
Footnotes :

11 EPA’s cost analysis does not even assess the costs associated with EPA’s proposed three

- year operating mode me asurement requirement. See "Memorandum

- Assessment of Impacts of the 2014 Proposed Revisions to Subpart W," Alexis McKittrick and Mark Defigueiredo, EPA/CCD, Docket ID No. EPA

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- 0063 (Feb. 20, 2014) at 3

- 5. Response: See response to comment EPA

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- A1, Excerpt 7 and Section II.B.11 of the preamble for additional discussion regarding the final requirements for compressor mode measurements

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85Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 14
Comment: Compressors Annual tests should be completed "as found" and Subpart W should not mandate a defined measurement frequency for any specific comp ressor operating mode. The Proposed Rule includes two new requirements that define the frequency for completing compressor vent measurements for a specific compressor operating mode. One requirement is a derivative of the current requirement to test recip rocating and centrifugal compressors in shutdown, de

- pressurized mode (hereinafter referred to as "shutdown mode" in this comment). The other is a new requirement to test centrifugal compressors in operating mode once every three years, or the next calenda r year that compressor operation exceeds 2,000 hours if operating mode is not measured in the previous three years. This is a new requirement, never before raised by EPA, and its addition has not been justified in the preamble or support documents. INGAA d oes not support these requirements and recommends testing compressors in the "as found" mode. Subpart W data collected to date indicates that collectively, measurements are being completed in all required compressor modes so industry data exists (and will continue to grow) to characterize emissions for each compressor mode

– source combination in §98.233(o) and (p). In summary, compressor measurements should be completed in the "as found" mode and EPA should not prescribe test frequency for any particular m ode. The preamble discusses options related to mandatory testing in shutdown mode and requests comment. It is INGAA’s understanding that inclusion of a mandatory frequency for shutdown mode tests in the current rule dates back to EPA concerns circa 2009

– 2010 that there would be a lack of data collected in this mode. However, 2011 and 2012 data demonstrate that T&S sources completed hundreds of measurements in this mode and there is approximately the same number of "as found" tests completed in shutdown mo de as other modes. Thus, it is not necessary to mandate testing in this or any mode. Mandating shutdown measurement frequency will result in unnecessary, additional emissions and costs, as well as logistical issues for scheduling out

- of

- sequence tests. For example, to accommodate logistical complications from mandatory shutdown tests, in some cases operating units will be shut down and blown down while test crews are completing their scheduled site visit. This results in unnecessary emissions and can have a cascade affect for other units and facilities where the mode may also be changed to address facility or system demands. Response: See response to comment EPA

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- A1, Excerpt 7 and Section II.B.11 of the preamble for additional discussio n regarding the final requirements for compressor mode measurements

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA)

86Document Control Number: EPA

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- A1 Comment Excerpt Number: 17
Comment: The Proposed Rule adds a new requirement for centrifugal compressors to complete operating mode tests every three years or the next year that compressor operation exceeds 2,000 hours if operating mode measurement is not completed in the previous three years. Thus, for centrifugal compressors, EPA has increased stringency without providing the regulatory basis, identifying the benefit, or justifying the data need. INGAA is strongly opposed to this revision since its need is unsubstantiated and Subpart W measurement data reported to date indicates hundreds of operating mode tests were completed in the first two years. The new requirement mandates measurement in operating mode at least once every three years or in a subsequent year when unit operation next exceeds 2,000 annual hours. EPA does not provide explanation or justification for this new requirement in the preamble or within any of the supporting documents. The time interval has no basis, and it is premature to establish any mandatory interval without first reviewing the 2011

– 2013 measurement data that has already been provided. Without any record supporting this arbitrary and capricious change, INGAA recommends deleting the requirement proposed in §98.233(o)(1)(i)(D). Similar to the discussion above, this requirement will add logistical problems, incur costs far in excess of EPA’s presumed costs for completing measurements, and result in scenarios where scheduling a third party contractor is not feasible. Based on experiences in 2011 and 2012, INGAA was surprised that the Proposed Rule retained

– and expanded

– mandatory schedules for mode

- specific tests. EPA should revise the proposed rule to eliminate mandatory mode

- specific test schedules and require annual measurement in the "as fo und" mode. As demonstrated in data reported to date, there is an abundance of data to review and analyze across all mode

- source combinations for both reciprocating and centrifugal compressors. Reported 2011 and 2012 data provide a reasonable number of meas urements in each mode, and additional data will be available from recently submitted 2013 data and data collected in 2014. Retaining the proposed requirements is unnecessary and will further increase compliance costs, introduce significant logistical chall enges, and require access to testing alternatives through missing data provisions. Response: See response to comment EPA

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- A1, Excerpt 7 and Section II.B.11 of the preamble for additional discussion regarding the final requirements for compressor mode measurements

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 24
Comment: Section 98.233(o)(1)(i)( D) requires centrifugal compressors be measured in the operating mode:

87− "...at least once in any three consecutive calendar years, provided that the measurement can be taken when the compressor is in operating

- mode. If three consecutive calendar years occur without measuring the compressor in operating

- mode, you must measure the compressor as specified in paragraph (o)(1)(i)(A) of this section in the next calendar year that the compressor is in operating

- mode for more than 2,000 hours." This new requirement in the Proposed Rule is not mentioned, discussed, or justified in the TSD. Further, the TSD fails to consider available data (i.e., reported emissions data by mode for 2011 and 2012) when assessing mandatory test frequencies for centrifugal compressors in the operating mode, and reciprocating and centrifugal compressors in the not operating, de

pressurized mode. EPA has not demonstrated that data from thousands of tests show a shortage of measurements for any particular compressor mode

- source combination, o r the need for the rule to mandate testing in any particular mode. Response: See response to comment EPA

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- A1, Excerpt 7 and Section II.B.11 of the preamble for additional discussion regarding the final requirements for compressor mode measurements

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Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Company (SoCal Gas) Document Control Number: EPA

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- A2 Comment Excerpt Number: 6
Comment: The Proposed Rule includes two new requirem ents that define the frequency for completing compressor source emission measurements for a specific compressor mode. One requirement is a derivative of the current requirement to test reciprocating and centrifugal compressors in the not operating depressu rized mode at least once every three years. The other requirement is new, and mandates that if a centrifugal compressor is not tested in the operating mode at least once in any three consecutive years, then the annual compressor measurement must be conduct ed in the operating mode the next year that operating hours exceed 2,000. Measurement data collected to date, however, do not support the need for these new test frequency requirements. SoCal Gas has about 43 compressors subject to Subpart W and has been m easuring compressor vent flows since 2011. Many measurements have been collected, which are more than adequate to characterize emissions for each compressor mode

- source combination in §98.233(o) and (p). There is no evidence that these mandates for compr essor vent measurement frequency will improve the measurement inventory. Furthermore, they will only introduce logistical complications for scheduling out

- of

- sequence tests and unnecessarily increase compliance costs. In addition, EPA has not demonstrated the need for, defined the benefit of, or estimated associated costs for the prescribed measurement interval mandates. EPA has not provided any explanation or justification in the preamble or within any of the supporting documents for the new measurement fr equency requirement for centrifugal compressors in operating mode. At a minimum, EPA should review and analyze 2011

- 2013 measurement data to ascertain any need

88prior to mandating any measurement frequencies. SoCal Gas operates compressors ranging from 25 HP

- 15,200 HP. Currently, the requirements for testing are the same for all compressors regardless of size or operation (ex. Vapor recovery). Based on an absence of support for these mandatory testing intervals, So Cal Gas recommends that all annual compre ssor source measurements be conducted in the as

- found compressor mode and that the mandatory testing interval subsections and associated reported activity data in the Proposed Rule be deleted. In addition, small, very low pressure compressors should be exc luded from the testing requirements, using a default population emission factor similar to LNG storage. Response: See response to comment EPA

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- A1, Excerpt 7 and Section II.B.11 of the preamble for additional discussion regarding the f inal requirements for compressor mode measurements

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

- HQ

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- 0081

- A1 Comment Excerpt Number: 49
Comment: Freq uency of Measurement in Shutdown, De

- pressurized Mode: EPA discussed options related to mandatory testing in shutdown, de

- pressurized mode and requested comment. It is INGAA’s understanding that mandatory frequency for shutdown mode tests is included in th e current rule due to EPA concerns that there would be a lack of data in this mode. However, 2011 and 2012 data show that T&S sources completed hundreds of measurements in this mode and there are about the same number of "as found" tests completed in shutd own mode as other modes. Thus, it is not necessary to mandate testing in this or any mode. Mandating shutdown measurement frequency will result in unnecessary emissions and costs as well as logistical issues for scheduling out

- of

- sequence tests. Response: See response to comment EPA

- HQ

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- 2011

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- 00 89

- A 3 , Excerpt 5 and Section II.B.11 of the preamble for additional discussion regarding the final requirements for compressor mode measurements

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Commenter Name: Thomas J. Bach Commenter Affiliation: Kind er Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Comment Excerpt Number: 21
Comment: EPA’s proposals to mitigate the burdens of the three

- year, mode

- specific testing requirements are also inadequate as proposed. Ackno wledging that its three

- year mode

- specific requirement "could present a compliance challenge for some facilities, because not every facility schedules routine shutdowns for maintenance within 3 years," EPA proposes to provide an exception to the three

- year requirement for compressors that do not undergo a "scheduled

89shutdown" during a three

- year consecutive period. For such compressors, emissions measurements in the not operating, depressurized mode can be made at the next "scheduled shutdown" (for reciproc ating compressors, during the next “scheduled shutdown” when the compressor rod packing is replaced). 13 EPA’s proposed "scheduled shutdown" exception to the three

- year requirement will not avoid many of the costs associated with mandatory testing in not op erating, depressurized mode, such as out

- of

- sequence scheduling costs or the obligation to maintain records on compressor shutdown testing status. However, the shutdown exception could provide relief to operators if it provides enough time for operators to coordinate the scheduling of third

- party measurement service providers with the scheduled shutdown. These measurements are usually scheduled several months in advance.
If EPA does not eliminate the three

- year, mode

- specific requirements, as Kinder Morgan requests, it should clarify the term "scheduled shutdown" to make the exception useful to operators. It could do so by clarifying that "scheduled shutdown" refers to a major maintenance outage that is scheduled months in advance, as opposed to a shutdown s cheduled in direct response to a particular event (e.g., in response to change in demand or operational disruption). Shutdowns are frequently scheduled to occur just days after a triggering event, and it would be logistically challenging and potentially im possible to schedule an internal Kinder Morgan or external contractor measurement team to perform an emission measurement in advance of these types of short

- notice shutdowns. Kinder Morgan believes that EPA intends for this "scheduled shutdown" exception t o refer only to major maintenance shutdowns with long lead times, and requests that EPA adopt a more specific definition.
Footnotes :

12 Proposed Rule at 13403.

13 Proposed §§ 98.233(o)(1)(i)(C) and (p)(1)(i)(D). Response: We are retaining, with minor revisions, the requirement to test in NOD mode at least once in any three consecutive calendar years, provided the measurement can be taken during a scheduled shutdown. If three consecutive calendar years occur without measurin g the compressor in NOD mode, you must measure the compressor at the next scheduled depressurized shutdown. We have clarified in the final rule that “... a scheduled shutdown means a shutdown that requires a compressor to be taken off

- line for planned or sche duled maintenance. A scheduled shutdown does not include instances when a compressor is taken offline due to a decrease in demand but must remain available.” See Section II.B.11 of the preamble for additional discussion regarding this comment

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 16

90Comment: For centrifugal and reciprocating compressors, the Proposed Rule spe cifies similar measurement requirements for not operating

- depressurized

- mode: §98.233(o)(1)(i)(C): "You must measure the compressor as specified in paragraph (o)(1)(i)(B) of this section at least once in any three consecutive calendar years, provided the m easurement can be taken during a scheduled shutdown . If three consecutive calendar years occur without measuring the compressor in not

- operating

- depressurized

- mode, you must measure the compressor as specified in paragraph (o)(1)(i)(B) of this section at the next scheduled depressurized shutdown ." [emphasis added] §98.233(p)(1)(i)(D): "You must measure the compressor as specified in paragraph (p)(1)(i)(C) of this section at least once in any three consecutive calendar years, provided the measurement can be taken during a scheduled shutdown . If there is no scheduled shutdown within three consecutive calendar years, you must measure the compressor as specified in paragraph (p)(1)(i)(C) of this section either prior to or during the next compressor shutdown whe n the replacement of the compressor rod packing occurs ." [emphasis added] Although the rule text includes a necessary qualification " provided the measurement can be taken during a scheduled shutdown, " ambiguity remains regarding what constitutes a shutdown

. Although EPA attempts to address issues with mandatory shutdown mode testing that resulted in many BAMM requests in 2013 (and likely 2014), practical concerns remain. It is unclear how a requirement for a test at the next "shutdown" would be interpreted. A number of companies have a corporate safety policy prohibiting or limiting standby, pressurized mode of operation when compressor operation is not required. In these cases, when a compressor is taken offline, it is depressurized (i.e., de

- energized) wit hin a specified time frame for safety reasons. Transmission compressors often start up and operate to meet pipeline demand; these compressor are then taken offline (i.e., "shutdown") when demand decreases. It is not clear if this "shutdown" meets the inten t of the revised rule text, and this interpretation would be a logistical impossibility to implement. In most instances, a unit taken offline (i.e., operation not needed due to pipeline demand) should not be considered "scheduled shutdown." Planning and mo bilization of a third party test group is not possible in this case and would be logistically difficult if not impossible. Third party mobilization would be extremely complicated even for planned shutdowns with a significant lead time. As noted above, INGA A members have tested nearly 1,000 total compressors, and tracking and scheduling systems will need to be developed and implemented to address this EPA requirement. It is not feasible or practical to mobilize a test crew to address a unit shut down on shor t notice. Most companies use third party contractors to complete annual measurements. Contractor crews are actively engaged in schedules where they proceed to affected facilities along a pipeline to complete annual measurements and then move on to the next pipeline. EPA has not considered the logistical issues for scheduling third party "out

- of

- sequence" tests or the additional costs and added burdens imposed by this requirement. As discussed in Comment 9, EPA cost estimates show a fundamental lack of under standing of measurement program

91requirements. While some situations may be able to accommodate this schedule, other situations will not have such flexibility. As a result, mandating shutdown measurement frequency in any form will yield an outcome that EPA wants to avoid: unnecessary vented methane emissions will occur as operators accommodate a mandatory shutdown mode test within the required three year (or five year) period. INGAA strongly believes that mandatory testing in shutdown mode is not warranted a nd has not been justified. Several items related to compressor "scheduled shutdown" and test scheduling must be considered:

• Some compressors start up and shut down frequently to meet pipeline demand, but may be operating or in standby mode when the "as fou nd" test is conducted. EPA should acknowledge that Gas Control operations dispatches compressors as necessary to meet demand and that unit shutdowns may occur that preclude a measurement. The rule text includes a necessary caveat regarding a scheduled shut down. It would appear to indicate that EPA intends for this requirement to apply to a shutdown of longer duration, such as those associated with major maintenance and a unit’s unavailability for dispatch. If EPA retains this approach, clarifying text shoul d be provided (e.g., preamble discussion) as well as a rule definition for "scheduled shutdown." Due to logistics, including test crew commitments and availability, significant lead time (e.g., multiple months) may be required to accommodate testing during a "scheduled" shutdown, and these complications must be considered in rule definitions and requirements.

• Even if EPA intends for scheduled shutdown to mean extended compressor shutdown for major maintenance, scheduling and logistical issues remain

– e.g., getting a test team to a site with relatively short notice; tracking shutdown test status and operations shutdown plans for each individual compressor. Most companies rely on third party service providers to conduct site surveys and measurements, which ar e often scheduled up to 6 months or more in advance, especially for the spring through fall (i.e., after early year cold weather and 1st quarter reporting is addressed and well in advance of the year

- end deadline). Attempting to align station operations an d maintenance with service providers increases the burden and costs, and may result in circumstances where a crew is not available, or would charge a significant additional fee. In addition, major maintenance activities may preclude safe measurement and so urce access due to the nature of the engine driver or compressor maintenance activities. In some cases, only essential staff members are allowed in proximity due to safety concerns.

• EPA has either not estimated or significantly under

- estimated costs and ha s not defined the benefit (or even demonstrated the need for a prescribed measurement interval) for this mandate. The existing count of mode

- specific Subpart W measurement data from 2011 and 2012 contradicts EPA’s perception that this provision is necessar y

• A s discussed in Comments 3 through 6, access to alternatives is imperative to address measurement challenges. Missing data provisions should be relied on when needed. Response: We are retaining, with minor revisions, the requirement to test in NOD mode at least once in any three consecutive calendar years, provided the measurement can be taken during a scheduled shutdown. If three consecutive calendar years occur without measuring the

92compressor in NOD mode, you must measure the compressor at the next sc heduled depressurized shutdown

. In the final rule, we are using consistent language for both centrifugal and reciprocating compressors to require reports that have not tested in the NOD mode for three consecutive years to test “...at the next scheduled depre ssurized shutdown.” We have also clarified in the final rule that “... a scheduled shutdown means a shutdown that requires a compressor to be taken off

- line for planned or scheduled maintenance. A scheduled shutdown does not include instances when a compresso r is taken offline due to a decrease in demand but must remain available.” See Section II.B.11 of the preamble for additional discussion regarding this comment

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of Amer ica (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 41
Comment: In §98.233(p)(1)(i)(D), it is not clear what is meant by "scheduled shutdown". Clarification is needed to provide operators a clearer understanding

– and there must be a reasonable, and potentially significant, lead time available to schedule and mobilize a test team. A similar clarification should be made for §98.233(o)(1)(i)(C). In both cases, significant lead time may be needed to address logistics, including test crew schedule and availability. INGAA does not support mandatory testing in shutdown mode. If that issue is addressed, then guidance on "scheduled shutdown" would not be necessary. Response: We have clarified in the final rule that “... a sche duled shutdown means a shutdown that requires a compressor to be taken off

- line for planned or scheduled maintenance. A scheduled shutdown does not include instances when a compressor is taken offline due to a decrease in demand but must remain available.” See Section II.B.11 of the preamble for additional discussion regarding this comment

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 64
Comment: In the preamble, EPA notes that they did not intend for reports to perform an unscheduled shutdown of a facility for the sole purpose of taking a measurement of the compressor in the not

- operating

- depressurized

- mode. API supports the revisi on to allow this measurement to be taken during the next scheduled depressurized shutdown. However, there are instances when a scheduled compressor shut

- down is only for a short duration, such that it is not possible to complete the measurement. In other s ituations, a “scheduled shutdown” may occur without sufficient lead time to arrange for or mobilize a measurement team. EPA has not

93considered the logistical requirements to arrange for and conduct these measurements. API requests some additional wording t o §98.233(o)(1)(i)(C) to address these issues: "...you must measure the compressor as specified in paragraph (o)(1)(i)(B) of this section at the next scheduled depressurized shutdown of sufficient duration and lead time ." Response: The clarification requested by the commenter is open to significant interpretation and could be used b y report er s as a means of not test ing during any scheduled shutdown. We have clarified in the final rule that “... a scheduled shutdown means a shutdown that requires a compressor to be taken off

- line for planned or scheduled maintenance. A scheduled shutdown does not include instances when a compressor is taken offline due to a decrease in demand but must remain available.” See Section II.B.11 of the preamble for additio nal discussion regarding the final requirements to measure compressors in the NOD mode

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number : 146
Comment: In the preamble, EPA notes that they did not intend for reporters to perform an unscheduled shutdown of a facility for the sole purpose of taking a measurement of the compressor in the not

- operating

- depressurized

- mode. API supports the rev ision to allow this measurement to be taken during the next compressor shutdown when the replacement of the compressor rod packing occurs. Response: The EPA thanks the commenter for their support. See Section II.B.11 of the preamble for additional discuss ion regarding the final the requirements to measure compressors in the NOD mode

.

Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Company (SoCal Gas) Document Control Number: EPA

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- A2 Comment Excerp t Number: 7
Comment: If the Proposed Rule measurement frequency by mode mandates are retained, then requirements associated with next scheduled depressurized shutdown should consider the logistics of conducting measurements and obtaining activity data. F or centrifugal and reciprocating compressors, the Proposed Rule specifies similar measurement requirements for the not operating depressurized

- mode: §98.2339o)(1)(i)(C): "You must measure the compressor as specified in paragraph (o)(1)(i)(B) of this section at least once in any three consecutive calendar years , provided the measurement can be taken during

94a scheduled shutdown . If three consecutive calendar years occur without measuring the compressor in not

- operating

- depressurized

- mode, you must measu re the compressor as specified in paragraph (o)(1)(i)(B) of this section at the next scheduled depressurized shutdown. " [Emphasis added] §98.233(p)(1)(i)(D): "You must measure the compressor as specified in paragraph (p)(1)(i)(C) of this section at least o nce in any three consecutive calendar years , provided the measurement can be taken during a scheduled shutdown . If there is no scheduled shutdown within three consecutive calendar years, you must measure the compressor as specified in paragraph (p)(1)(i)(C ) of this section either prior to or during the next compressor shutdown when the replacement of the compressor rod packing occurs. " [Emphasis added] §98.236 (o)(l)(xvi) "Date of last maintenance shutdown that compressor was depressurized" (p)(l)(xvi) "Dat e of last maintenance shutdown for rod packing replacement" Although the rule text provides a qualification "provided the measurement can be taken during a scheduled shutdown" regarding the mandated test schedule, there is ambiguity regarding what constitu tes a scheduled shutdown, and practical considerations remain. Primary concerns include:

• When taken out of service or shut

- down, a unit may not be depressurized (i.e., de

- energized). Depressurization might only occur during major equipment overhaul dependi ng upon the facility operating configuration.

• Planning and mobilization of a test team can be logistically difficult, even for planned shutdowns with a significant lead

- time. It is not feasible or practical to mobilize a test crew to address a unit shut do wn on short notice because they are typically actively engaged in test schedules to complete annual measurements. EPA has not considered the logistical issues for scheduling "out

- of

- sequence" tests or the additional cost or added burden imposed by this req uirement. Because operators are obligated to dispatch compressors as necessary to meet demand, unit shutdowns may occur that preclude a measurement. The Proposed Rule needs a practical definition regarding a scheduled shutdown that includes a shutdown of l onger duration and likely associated with major maintenance and unit unavailability for dispatch. SoCal Gas proposes the following:

• "for the purposes of this testing, "scheduled shutdown" is a shutdown that plans for the unit to be taken out of service, in cludes compressor depressurization, and that is scheduled at least three weeks in advance and has a duration no less than 96 hours." Response: The clarification requested by the commenter has specificity . In response to public comments, w e have clarified in the final rule that “... a scheduled shutdown means a shutdown that requires a compressor to be taken off

- line for planned or scheduled maintenance. A scheduled shutdown does not include instances when a compressor is taken offline due to a decrease in dem and but must remain available.” While we have not provided a minimum lead

95time or duration for the scheduled shutdown , this revision clarifies our intent that the maintenance has to be planned or scheduled in advance and that the maintenance requires that the compressor be taken off

- line (depressurized) to be considered a scheduled shutdown

. See Section II.B.11 of the preamble for additional discussion regarding the final requirements to measure compressors in the NOD mode

.

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

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- A1 Comment Excerpt Number: 11
Comment: Although we have not used the BAMM provisions to date, BAMM has typically been used to estimate emission s from equipment that is not available in a specific operating mode at the time of the annual measurement survey; for example, compressor vents are required to be measured in a "depressurized, not operating" mode every three years. It may not be possible t o conduct this measurement without interrupting natural gas service since units may be required to be operating at the time of the survey to provide natural gas to customers. The proposed rule seeks to address this situation by allowing operators to measur e this mode during a scheduled shutdown. If there is no scheduled shutdown within three consecutive calendar years, then a measurement would have to be made during the next scheduled depressurized shutdown. EPA has specifically requested comment on the opt ion of requiring measurement in this mode every five years rather than every three years to provide companies a larger window of opportunity to make the measurement. We request extension of the required monitoring frequency to once every five years to prov ide additional flexibility in monitoring, however, this change will not result in 100% certainty that a unit will be available at a specific time. This requirement should be vie wed in conjunction with the "mi ssing data" provisions and emission factors deve loped for this operating mode as soon as feasible, since this is one of the most problematic emissions measurements to obtain. Response: See response to comment EPA

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- A 3 , Excerpt 5 and Section II.B.11 of the preamble additional discuss ion regarding the final requirements to measure compressors in the NOD mode

. 

### 15.5 Use of as found leak measurements to develop reporter emission factors in Eq uatio ns W
- 23 and W
- 28.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Docume nt Control Number: EPA

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Comment: Proposed EPA Amendment: For reporters that elect to conduct as

- found leak measurements for individual compressor sources, all measurements from a single owner or

96operator may be used when developing emission factors. These emissions factors must be applied to all reporting facilities for the owner or operator. Williams is supportive of the amendment, as it allows more measurements to be used in calculating representative c ompressor emission factors for the various compressor mode

– source combinations. Response: The EPA thanks the commenter for their support. These revisions are finalized as proposed.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: API also supports the change and appreciates EPA revising the rule language to include a clear option to calculate the compressor emissio n factor using either measurements from a single facility, or using all measurements from a single owner or operator. However, the current and proposed rule language leave room for interpretation as to what is meant by “reporter” as no definition was inclu ded in the rule. A Frequently Asked Questions document published by EPA in July 2011 provided clarification to the entity EPA considered to be the “reporter” for purposes of calculating compressor emission factors to be applied to emissions not measured du ring the annual test (inserted below). If the proposed change is included in the final rule, API recommends that EPA include language in the rule that addresses the meaning of “reporter” as addressed in the FAQ included below. Question : Need clarification on what entity the “reporter” is in terms of developing the compressor emission factors for measurements conducted in the “as found” mode and applied to other compressors. This applies to processing, storage, transmission, and LNG operations. Is the “repor ter” the facility, or all facilities operated by the same company? Response : For purposes of developing the compressor emission factors for measurements conducted in the “as found” mode, EPA intended the “reporter” to be all facilities operated by the same company. In other words, the company could develop an emission factor, and apply it to all facilities operated by the same company. EPA has reviewed your question and cannot provide further guidance at this time. Your question relates to an issue or issue s currently the subject of ongoing litigation. Please monitor the website for any additional guidance that may be available in the future. http://www.epa.gov/climatechange/emissions/subpart/w.html Response: The EPA evaluated the commenter’s concerns and ha s determined the rule does not need to be revised. As allowed at § 98.233(o)(6)(iv) and § 98.233(p)(6)(iv) of the final rule, the reporter emission factor may be calculated by using all measurements from a single owner or operator instead of only using measu rements from a single facility. If you elect to use this option,

97the reporter emission factor must be applied to all reporting facilities for the owner or operator. No change has been made to the final rule as a result of this comment.

Commenter Name: R itu Talwar Commenter Affiliation: Spectra Energy Corp Document Control Number: EPA

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Comment: As stated in the current rule, section 98.233(o)(6)(i) and 98.233(p)(7)(i)(B) , the 3

- year average is develope d by creating an annual emission factor and then averaging the 3 years. However, as newly written, the proposed Equations W

- 23 and W

- 28 have more specific language that requires taking all 3 years of data to develop the average, thereby, eliminating the an nual average. Equation flexibility is needed to maintain the annual average to avoid unnecessary costs and reporting burden of modifying existing data systems. Response: The EPA disagrees with the commenter ’s interpretation of the existing requirements in the current rule at § 98.233(o)(6)(i) and § 98.233(p)(7)(i)(B)

. The current rule at § 98.233(o)(6)(i) and § 98.233(p)(7)(i)(B) requires reporters to use all measurements from the current calendar year and the preceding two calendar years (totaling three consecutive calendar years of measurements) to calculate the annual emission factor. The current rule does not allow the reporter to calculate an annual average emissions factor and then average three annual average emissions factors together. However, we note that, if one retains the so

- called “annual average emissions factors” and the count of compressors measur ed during each year, one can easily calculate the correct average emissions factor (weighting each annual emission factor by the number of measurements made during each year of the three year period). No change has been made to the final rule as a result o f this comment.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number: 11 Comment Excerpt: ( g) 98.236(o)(2)(vii) "...For emission vents asso ciated with individual compressor sources that use an as found leak measurement(s), calculate emissions by summing all emissions from all compressor mode

- source combinations for the emission vent." If this requirement is kept in the final rule, this calcul ation requirement should be housed in 98. 233 (o)(6) under a new requirement 98.233(o)(6)(v). Since it is a required calculation, it should not be described in the reporting section of the rule. This same comment and suggested correction also applies to the analogous requirements in 98.236(p) and 98.233(p). Response: The provision noted by the commenter was inadvertently included in the proposed rule. Similar to the requirements in the current rule, the EPA intended to have the emissions reported separately for each compressor source at each compressor as specified in the proposed

98rule at §98.236(o)(2) and (p)(2). In the final rule, the reporting requirements for compressors ha ve been revised to more clearly indicate that the reporting requirements apply to e ach compressor source leak or vent. We recognize that manifolded compressors and compressors with continuous leak measurements may include emissions across different compressor sources, but for single compressors using at found measurements, emissions reporting will be the same as in previous years (by compressor source for each compressor)

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### 15.6 Comments on other minor revisions and restructuring of reporting requirements for centrifugal and reciprocating compressors

Commenter Name: Lisa Beal Commenter Aff iliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: The proposed revision that eliminates acoustic device measurement for blowdown valves is arbitrary and capricious. The previous comment notes instances where acoustic instruments are allowed for leak detection , and Subpart W also includes the acoustic leak detection device for leak rate quantification in §98.234(a)(5). However, the Proposed Rule introd uces new limitations for using the acoustic device method for quantifying through

- valve leakage. As discussed in Comment 13, EPA must re

- visit its decisions in previous amendments to understand the significant problem this change causes, because EPA added the acoustic method for leak quantification in an attempt to remedy June 2010 comments on the re

- proposed Subpart W rule. The 2010 Subpart W Final Rule added the acoustic method for leak quantification for measurements where through

- valve leakage is the em ission source, including transmission condensate tank dump valves, compressor isolation valves, and compressor blowdown valves. The Proposed Rule eliminates use of the acoustic method for blowdown valve leakage measurements for reciprocating compressors in operating mode or standby pressurized mode, and centrifugal compressors in operating mode. This revision is not explained or justified. In addition, as discussed in the following comment, eliminating this method will introduce significant compliance chall enges for operators. Since EPA added the method to Subpart W in an attempt to respond to comments regarding safety issues for some vent measurements, elimination of the acoustic method for vent measurements associated with blowdown valve leakage undermines EPA’s perceived solution to INGAA’s comments. Since addition of the acoustic method was EPA’s solution to measurement challenges, this proposed revision compromises the ability of operators to comply. During the 2010 rulemaking, other recommendations offe red by INGAA were not implemented by EPA. Operators did not necessarily agree with EPA’s decision to add the acoustic method, as opposed to alternative approaches or other measurement methods, including the IR camera. However, the acoustic method is now in tegral to Subpart W compliance. Revisions to method applicability is unsupported in the preamble or background documents. Elimination of the acoustic method for blowdown valves is untenable unless the

99original comments from INGAA and others are revisited. Comment 13 provides additional background and details regarding this issue. Response: The EPA has retained the acoustic device measurement method in the final rule. See Section II.B.11 of the preamble to the final rule for additional discussion respon ding to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: EPA cannot eliminate use of acoustic device measurement unless significant other issues are addressed. The Proposed Rule eliminates acoustic device measurement for compressor blowdown valve leakage. As discussed above, EPA has not explained this revision. During the 2010 Subpart W rulemaking , INGAA offered other recommendations to address vents that are unsafe to access or technically infeasible to measure through both its written comments and during industry meetings with EPA; INGAA would be open to revisiting this issue. However, based on E PA’s 2010 decisions as reflected in the November 2010 Subpart W Final Rule and explained in EPA’s responses to comments, the acoustic method is integral to the ability of operators to meet Subpart W measurement obligations. Use of the acoustic device must be retained without revisions or significant other issues must be addressed. Since 2009, there has been considerable discussion about the inability of operators to safely access or feasibly measure all vents. Through comments and meetings with EPA, INGAA explained scenarios of concern and offered several recommendations. EPA can reference INGAA comments from June 2010, as well as other timeframes for additional detail, but example issues and recommendations included:

• The primary consideration in the design and construction of compressor

- related vents is to safely convey potential gas leakage outside of the compressor house. Measurement or access to these vents was not contemplated in station design. In some cases, vent lines are only "accessible" at or abov e the compressor house roofline because compressor house equipment and other lines preclude adding access ports at a lower elevation. In addition, in some cases it may not be safe to access lines at the roofline because ground

- level piping and equipment i n the vicinity preclude safe access. INGAA has explained this issue in detail and provided example pictures in previous comments and meetings.

• INGAA comments and discussions with EPA requested the ability to preclude measurement of vent lines that were ina ccessible due to safety and other feasibility issues (e.g., line masked by other equipment). INGAA and its members were confident that the majority of lines could be accessed and measurements completed. However, since measurement had

100never been required fo r these lines, the prevalence of lines infeasible to measure was uncertain.

• It was noted that rule implementation would document the prevalence of vents infeasible to measure, and INGAA members were confident that the vast majority would be measured. In ad dition, other measures, such as IR camera screening of elevated inaccessible vents, could be completed to document the prevalence of leakage and vent emissions from inaccessible lines.

• INGAA and its members were confident that measurement program implement ation would document a very high percentage of vent line measurements representative of the population of T&S compressors, especially after measures were implemented to address challenging situations. INGAA recommended phasing in the measurements over the first few years (or access to BAMM) to provide time for operators to engineer solutions (e.g., add sample ports during maintenance shutdown) for vent lines with access complications.

• INGAA and its members were willing to work with EPA to identify a minimum threshold of measured lines (i.e., the vast majority) and requirements to document measurement issues and leak frequency (based on IR camera screening) for vents not measured. This approach could have been linked to an alternative data quality objective t o replace EPA’s "100% measured" goal, as discussed in Comment 11. This approach would provide ample data to develop reporter emission factors and support documentation for vents not measured. In addition, proven direct measurement methods would have been u sed for the very high percentage of vent lines measured. It would not have been necessary to add the indirect acoustic method to Subpart W. However, EPA insisted on measurement of every vent. In response to comments from INGAA and others regarding vent lin es that are not safe to access or infeasible to measure, EPA added the acoustic method for leak quantification to the Subpart W Final Rule in November 2010. Prior to its inclusion in the final rule, that method had not been discussed as an alternative. ING AA comments regarding flexibility for leak detection had requested the addition of acoustic instruments for detecting through valve leakage, and it was INGAA’s understanding that the instrument functions well for leak detection . However, acoustic device le ak rate quantification was added to Subpart W as EPA’s solution to these concerns, as evident in the November 2010 Response to Comments Document 12 (as well as the 2010 Technical Support Document). For example, EPA responses to comments about safety and ven t measurement feasibility repeatedly identify acoustic device measurement as the solution. Several example EPA responses are provided: "EPA recognizes the importance of ensuring safety. Rather than provide exemptions, EPA has added alternative reporting me thodologies to ensure safety in the collection of data from certain sources. ... EPA has added in today’s final rule alternative emissions estimating methods which can be performed safely when direct, end of stack emissions measurement is deemed unsafe or le ss economical for the reporter. For gas processing, transmission, storage, LNG storage and LNG import/export terminals, today’s final rule provides options of installing ports in vent lines which are unsafe to access the end of the vent stack, or, ... the us e of acoustic detectors which

101have algorithms for equating detector readings with through

- valve leakage." [Response to Comments, Pages 2

– 3] "Finally, EPA is very aware of safety issue, and today’s final rule adds several alternative emissions detection a nd quantification options to be more cost

- effective as well as less hazardous... today’s final rule allows the alternative to use an acoustical detector calibrated for through

- valve leak quantification as an alternative to condensate tank roof vent measureme nt. This same technique is included for through leaking compressor isolation valves." [Response to Comments, Page 267] "In addition, EPA has added options for quantifying emissions as alternative to direct measurement of today’s final rule. For example:

• Fo r condensate tank emissions at transmission compressor stations (i.e. leaking scrubber dump valves), these emissions can also be estimated by the alternative of testing the dump valve directly with an acoustic detector that has an algorithm to estimate thr ough valve leakage flow.

• Reciprocating compressor packing vents and blowdown vents also allow use of an acoustic detector that quantifies flow. Measurement can also be done by simple piping reconfiguration to put a leg of the vent piping out where it can b e easily accessible for insertion of a portable flow meter (e.g. hot wire anemometer)

• Centrifugal compressor wet seal oil degassing vent and blowdown vents can also use the acoustic detector for through leaking blowdown valves.

• All compressor isolation val ves can be measured at the blowdown vent or, alternatively, with an acoustic detector at the valves themselves." [Response to Comments, Page 291] "EPA disagrees with the use of an engineering analysis to quantify venting emissions from through

- valve leakag e. These methods will not accurately quantify venting emissions from a significant source of emissions to adequately inform future policy decisions. However, today’s final rule has been revised and EPA is allowing the use of an acoustic leak detection inst rument to detect and measure venting emissions from through valve leakage from transmission tanks, and centrifugal and reciprocating compressor venting." [Response to Comments, Page 1297] "EPA agrees that safety should be a primary concern of reporters whe n monitoring transmission storage tanks; please see the response to EPA

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- 11. Of particular note, EPA allows the installation of permanent flow meters and the use of acoustic instruments so reporters can monitor these sources remotely a nd therefore never compromise safety." [Response to Comments, Page 1456] "In gas transmission compressor stations, EPA has included in today’s final rule the alternative of using an acoustic leak detection instrument that has algorithms for through

- valve l eak quantification to estimate compressor scrubber dump valve leakage as an alternative to measuring the emissions from the tank roof vent. This alternative acoustic through

- valve leak measurement technique is also added in today’s final rule for compresso r blowdown vent through

- valve leakage." [Response to Comments, Page 1511]

102These are just some of the examples; there are additional examples in the Response to Comments Document. The responses are sometimes specific to one or two of the types of valves rel ated to vented emission measurement, but it is clear that EPA adopted the acoustic method for leak rate measurement as the solution to safety and vent measurement feasibility issues wherever through

valve leakage is the emission source that triggers a vent measurement requirement. This decision was intended to address EPA’s desire to ensure that 100% of vents are measured. This EPA decision has resulted in important implementation outcomes, including:

• In some instances, the acoustic method has been used for vent measurements where the associated valve is accessible and direct vent measurement was not required because of acoustic method availability.

• In the first three reporting years, many reciprocating compressor and centrifugal compressor measurements of i solation valve and blowdown valve leakage, and condensate tank dump valve leakage, have used the acoustic method. Data reported to e

- GGRT for these years cannot discern acoustic method data from data acquired using direct measurement methods (e.g., meter o r anemometer in the line, bagging, high volume sampler).

• There are questions arising about whether measurement methods contribute to the difference in compressor methane emission estimates for Subpart W versus the U.S. GHG Inventory. Note that despite the addition of the acoustic method, BAMM requests have still been necessary to address cases where neither the vent line nor valve is accessible. For example, valves are sometimes buried or insulated and thus inaccessible. If the vent line is also inaccessibl e or infeasible to measure, INGAA does not expect that EPA wants a valve exhumed for acoustic device measurement. Since EPA’s solution to measurement challenges was addition of the acoustic method, the method has been used by operators to comply with Subpa rt W requirements. It is notable that an EPA GHG emission factor project being conducted in the same timeframe, managed by the same group that authored Subpart W, discussed acoustic method results in a 2011 report 13

. EPA’s decision to rely on the acoustic method as the "silver bullet" for measurement concerns has resulted in a method that is now inextricably woven into the fabric of the rule

– and must remain a measurement option unless the numerous issues raised since 2009 are revisited. In addition, any a ttempt to reconcile the issues will require time for operators to assess and implement any new "solution." The history summarized above

– and elaborated on in more detail in previous INGAA comments and EPA’s 2010 Response to Comments document

– demonstrate s that the use of the acoustic method cannot be altered without undermining previous decisions that affect the ability of operators to comply. The Proposed Rule revision to eliminate use of the acoustic method in some cases cannot stand. INGAA welcomes add itional conversation on this topic, with the understanding that any attempt to alter the current rule must undertake a thorough and thoughtful process to define acceptable alternatives to the current measurement paradigm. It is imperative that revisions do

103Footnotes :

12 "Mandatory Greenhouse Gas Reporting Rule Subpart W

– Petroleum and Natural Gas: EPA's Response to Public Comments," (November 2010).

13 Natural Gas Industry Methane Emission Factor Improvement Study . Final Report, Cooperative Agreement No. XA

- 83376101, prepared for U.S. EPA by URS Corporation and University of Texas

– Austin (December 2011). Response: The EPA has retained the acoustic device measurement method in the final rule. See Section II.B.11 of the preamble to the final rule for addi tional discussion responding to this comment.

Commenter Name: Ritu Talwar Commenter Affiliation: Spectra Energy Corp Document Control Number: EPA

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Comment: Acoustic Measurement Device is an Acceptabl e Compliance Method for Subpart W and Proposed Limitations Reduce Measurement Flexibility : The Proposed Rule eliminates use of the acoustic method for blowdown valve leakage measurements for reciprocating compressors in operating mode or standby pressurize d mode, and centrifugal compressors in operating mode. We question the rationale for this revision and the lack of meaningful explanation for the change. Eliminating this method will introduce significant compliance challenges for the transmission and stor age sector. For example, Spectra Energy uses an acoustic device to measure potential leaks through blowdown valves as an alternative to measuring valve leaks at vent stacks, as prescribed in 40 CFR 98.233. Spectra Energy believes that, in these instances, measuring leaks using an acoustic detection device is a safer alternative for Spectra Energy ’ s employees and contractors. Because of these efforts to provide an efficient and safe method for leak detection in certain situations, Spectra Energy encourages E PA to continue to allow the use of acoustic measuring devices. Response: The EPA has retained the acoustic device measurement method in the final rule. See Section II.B.11 of the preamble to the final rule for additional discussion responding to this comm ent.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: EPA is eliminating the use of acoustic device measurement for blowdown valve leakage for centrifugal compressors in operating mode. API objects to this revision as there may

1 04be situations where it is unsafe or infeasible to otherwise measure these emissions. EPA had added this provision to remedy issues raised in Jun e 2010 comments on the re

- proposed Subpart W rule. Removing this option is further complicated by EPA’s proposal to remove the option to request BAMM, introducing compliance challenges for operators using acoustic device measurements for blowdown valve lea kage. Response: The EPA has retained the acoustic device measurement method in the final rule. See Section II.B.11 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Karin Ritter Commenter Affiliatio n: American Petroleum Institute (API) Document Control Number: EPA

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Comment: EPA is eliminating the use of acoustic device measurement for blowdown valve leakage for reciprocating compressors in operat ing mode or standby pressurized mode. API objects to this revision as there may be situations where it is unsafe or infeasible to otherwise measure these emissions. EPA had added this provision to remedy issues raised in June 2010 comments on the re
- propos ed Subpart W rule. Removing this option is further complicated by EPA’s proposal to remove the option to request BAMM, introducing compliance challenges for operators using acoustic device measurements for blowdown valve leakage. Response: The EPA has ret ained the acoustic device measurement method in the final rule. See Section II.B.11 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Ga s Company (SoCal Gas) Document Control Number: EPA

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Comment: The Proposed Rule eliminates acoustic device measurement for compressor blowdown valve leakage, but still requires measuring 100% of vents. Cu rrently, SoCal Gas relies on this measurement method to address blowdown vents where vents are not accessible due to safety considerations precluding direct measurement. Therefore, use of this device cannot be eliminated unless alternative rule requirement s are provided such as the infrared camera for screening and eliminating the requirement to measure 100% of vents (I.e., inaccessible, unsafe, or technically infeasible to measure). Response: The EPA has retained the acoustic device measurement method in the final rule. See Section II.B.11 of the preamble to the final rule for additional discussion responding to this comment.

105Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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Comment: In 40 CFR 298.233(o)(2)(i) and (p)(2)(i), EPA has eliminated the use of acoustic leak detection devices for measuring natural gas leakage through blowdown vent valves when the centrifugal or reciprocating compressor is pressurized. Previously, this was allowed. Williams’ monitoring contractor often uses an acoustic leak detection device across blowdown vent valves in cases where other measurement methods are not safe or possible. Elimination of this measurement method for blowdown vents would reduce the number of actual vent measurements collected and would be detrimental to the GHG inventory program. The acoustic leak detection device is a safe and simple method for measuring leaking blowdown valves. Eliminating this measurement method would create unintended safety hazards. One hazard is having to use a manlift in unsafe surroundings (overhead power lines, physical obstructions) to measure blowdown valve emission s from elevated blowdown stacks. A second hazard is subjecting individuals collecting the measurements to the possibility of collecting the measurement when a high

- pressure blowdown occurs. Response: The EPA has retained the acoustic device measurement me thod in the final rule. See Section II.B.11 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Several miscellaneous minor technical corrections and clarifications were identified. The Proposed Rule has not been scrutinized for minor corrections. The limited time for comment preparation, and schedule overlap with reporting obligations due March 31, prevented such scrutiny. However, several minor technical corrections and requests for clarification are included here. In some cases, comments above could result in revisio ns that would make these items irrelevant (i.e., the item in question would not be in the Final Rule).

• Since timing did not provide the opportunity to "test" the data flow and calculations in the compressor sections, INGAA recommends that the compressor se ctions be carefully reviewed to ensure the source(s), and associated compressor(s) operation and measurements

106for all reported emissions are clear and concise, and are consistent with data collected and emissions calculated by the equations in §98.233(o) a nd (p).

• EPA should clarify the requirements for compressor sources routed to vapor recovery. The following recommendations to delete text clarify that no measurement or additional data are required if the compressor vent is routed to vapor recovery:

− §98. 233(o): "...If emissions from a compressor source are routed to vapor recovery, paragraphs (o)(1) through (o)(12) of this section do not apply."

− §98.233(p): "...If emissions from a compressor source are routed to vapor recovery, paragraphs (p)(1) through (p) (12) of this section do not apply." Response: The EPA agrees with the commenter’s suggested corrections and has revised the rule accordingly

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Section 98.233(p) states that when emissions from a compressor source are routed to vapor recovery, the calculations specified in paragraphs(p)(1) through (p)(12) do not apply. It appears that this is intended to eliminate all requirements in paragraphs (p)(1)

– (12), but this is not clear because "calculations" is referred to in the regulatory text (i.e., it could be interpreted that requirements not related to cal culations apply). Text should be revised so that it is clear that all of the requirements in paragraphs (p)(1)

– (12) do not apply. A similar clarification should be made for §98.233(o). "... If emissions from a compressor source are routed to vapor recovery , paragraphs (p)(1) through (p)(12) of this section do not apply. ..." Response: The EPA agrees with the commenter’s suggested corrections and has revised the rule accordingly

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Asso ciation of America (INGAA) Document Control Number: EPA

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Comment: To alleviate possible confusion and facilitate understanding of subsequent calculation and reporting requirements, it is recommended tha t the phrase "compressor mode

– source combination" be introduced in §98.233(p)(1)(i) and that the four specific compressor

107mode

– source combinations be listed. A similar revision should be made for §98.233(o)(1)(i) for the three centrifugal compressor mo de

- source combinations. Response: The EPA has evaluated the commenter’s concerns and has determined the rule does not need to be revised. The requirements at § 98.233(o)(1)(i)(A) and (B) and § 98.233(p)(1)(i)(A) through (C) clearly identify the compressor m ode

- source combinations that require an emission factor. No change has been made to the final rule as a result of this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Numb er: EPA

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Comment: Text that follows related to manifolded line measurements is confusing and appears to contain a typo. It appears that "two" should be "three". It is unclear whether each measurement must be 60 days apart or if there must be 60 days between the first and last (third) measurement.

• §98.233(o)(1)(iii)(C): "The three required leak measurements must be separated by a minimum of 60 days. If more than two three leak measurements are performed , the first and last measurements in a calendar year must be separated by a minimum of 120 days." Response: The EPA is not requiring three annual measurements for manifolded vents in this final rule. See Section II.B.11 of the preamble to the final rule f or additional discussion regarding the final requirements for manifolded compressors

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Clarifying revisions are recommended to correct a grammatical inconsistency when referring to standard conditions. The following sections should be revised by replacing the word "Measure" with "Determine" for both reciprocatin g and centrifugal compressor sections. Neither should request "measurement" at standard conditions; rather, the measured values should be adjusted to standard conditions:

• §98.233(o)(2)(i)(A): " Measure Determine the volumetric flow at standard conditions fr om the blowdown vent using calibrated bagging or high volume sampler according to methods set forth in § 98.234(c) and § 98.234(d), respectively."

• §98.233(o)(2)(i) (B): " Measure Determine the volumetric flow at standard conditions from the blowdown vent using a temporary meter such as a vane anemometer according to methods set forth in § 98.234(b)."

108• §98.233(p)(2)(i)(A): " Measure Determine the volumetric flow at standard conditions from the blowdown vent using calibrated bagging or high volume sampler acco rding to methods set forth in §98.234(c) and §98.234(d), respectively."

• §98.233(p)(2)(i) (B): " Measure Determine the volumetric flow at standard conditions from the blowdown vent using a temporary meter such as a vane anemometer, according to methods set f orth in §98.234(b)." Response: The EPA agrees with the commenter’s suggested edits and has subsequently revised the rule. In addition, the EPA has made analogous edits to § 98.233(p)(2)(ii)(A) and (B) for consistency.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Suggested clarifying text revisions for §98.233(p)(2)(iii)(A):
"You must use the meth ods described in § 98.234(a) to conduct annual leak detection of equipment leaks from the packing case into an open distance piece, or for compressors with a closed distance piece, conduct annual detection of gas emissions from the rod packing vent, distan ce piece vent, compressor crank case breather cap or other vent emitting gas from the rod packing ." Response: The EPA agrees with the comme nter’s suggested edits and has revised the final rule accordingly

.

Commenter Name: Lisa Beal Commenter Affiliatio n: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: §98.236(p)(2)(vii) requires: "For emission vents associated with individual compressor sources that use a n as found leak measurement(s), calculate emissions by summing all emissions from all compressor mode

source combinations for the emission vent" It is not clear why this would be required. Reporting the emissions for compressor mode

- source combinations sep arately could provide additional insight into the emission source, and the values can be summed at any time. In addition, it is not clear if this requirement only applies when the emissions are all measured values, or if it applies when one or more of the emission rates are calculated from the reporter emission factor using equation W

- 27.

109Response: The provision noted by the commenter should not have been included in the proposed rule. Similar to the requirements in the current rule, the EPA intended to ha ve the emissions reported separately for each compressor source at each compressor as specified in the proposed rule at §98.236(o)(2) and (p)(2). In the final rule, the reporting requirements for compressors ha ve been revised to more clearly indicate that the reporting requirements apply to each compressor source leak or vent. We recognize that manifolded compressors and compressors with continuous leak measurements may include emissions across different compresso r sources, but for single compressors using at found measurements, emissions reporting will be the same as in previous years (by compressor source for each compressor)

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GP A) Document Control Number: EPA

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Comment: Incorrect equation reference: 98.236(o)(3) says "...If the measurement method specified in paragraph § 98.233(o)(2) is performed, report the information specified in paragraph (o)(3)(ii) of this section." This sentence does not make sense and must be in error. 98.233(o)(2) is solely for "as found" measurements from individual compressor sources. However, the requirements of 98.236(o)(3)(ii) related to instances whe re a reporter uses equation W

- 24, which is only used for continuous monitoring and measurements of manifolded groups of compressor sources. Although we are unclear what the intended requirement is, a possible suggested correction is as follows, but we enco urage EPA to discuss this item with GPA. 98.236(o)(3)(ii) For each compressor mode

- source combination where a reporter emission factor as calculated in equation W

– 24 W
- 23 was used to calculate emissions in Equation W

– 23 W

- 22 , report the information specifi ed in paragraphs (o)(3)(ii)(A) through (o)(3)(ii)(D) of this section
. (B) The compressor mode

- source combination reporter emission factor, in standard cubic feet per hour (EFm,s in Equation W

– 24 W
- 23 ). (C) The total number of compressors measured in the compressor mode

- source combination in the current reporting year and the preceding two reporting years (Countm in Equation W

– 24 W
23 ). Response: The EPA agrees with the comme nter’s suggested edits and has revised the final rule accordingly

.

Commenter N ame: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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110Comment: • Suggested clarifying edits to §98.233(o)(6)(i) and §98.233(p)(6)(i) "Tm = Total time the compressor is in the operating mode associated with the mode

- source combination m, for which Es,i,m is being calculated , in the reporting year, in hours." • Suggested clarifying edits to §98.233(o)(6)(ii) and §98.233(p )(6)(ii) "Tm = Total time the compressor is in the operating mode associated with the unmeasured mode

- source combination m, for which Es,i,m is being calculated , in the reporting year, in hours." Response: The EPA disagrees with the commenter’s suggested clarifying edits because the term “operating mode” refers to only one of several different compressor modes. The requirements at § 98.233(o)(6) and § 98.233(p)(6) apply to all compressor mode

- source combinations. The final rule defines “compressor mode” and “compressor source” at § 98.238. No change has been made to the final rule as a result of this comment.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: Conflicting requirements for reciprocating compressor emission factors: 98.233(p)(6)(iii)(A) and (B) are contradictory requirements. 98.233(p)(6)(iii)(A) requires that an emission factor "must be calculated annually for each compressor mode

- source..." (emphasis added). However, 98.233(p)(6)(iii)(B) then says, "You must combine emissions for blowdown vents, measured in the operating and standby

- pressurized modes." We suggest the follow ing changes: 98.233(p)(6)(iii) Using Equation W

– 28 of this section, develop an emission factor for each compressor mode
- source combination specified in paragraph (p)(1)(i)(A), (p)(1)(i)(B), and (p)(1)(i)(C) of this section the compressor mode
- source combinations specified in paragraphs (p)(6)(iii)(A) through (C) . These emission factors must be used in Equation W

– 27 of this section to determine volumetric emissions from a reciprocating compressor in the mode

- source combinations that were not measured i n the reporting year. 98.233(p)(6)(iii)(A) Emission factors must be calculated annually for each compressor mode
source combination specified in paragraph ((p)(1)(i)(A), (p)(1)(i)(B), and (p)(1)(i)(C) of this section. 98.233(p)(6)(iii) (B) You must combi ne emissions for blowndown vents, measured in the operating and standby
- pressurized modes. 98.233(p)(6)(iii)(A) Rod packing in operating
- mode.

11198.233(p)(6)(iii)(B) Blowdown valve leakage in operating
- mode and standby
- pressurized
mode. You must combine em issions for blowdown vents, measured in the operating and standby
- pressurized modes. 98.233(p)(6)(iii)(C) Isolation valve leakage in not
- operating
- depressurized
- mode. Response: The EPA has evaluated the commenter’s concerns and agrees that there are con flicting provisions in the proposed rule. W e have determined that the proposed provision in §98.233(p)(6)(iii)(B) is the incorrect provision and should be deleted. In the final rule, we have revised §98.233(p)(6)(iii) to state that the emission factors mus t be calculated annually and we have deleted proposed § 98.233(p)(6)(iii)(A) and (B)

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment E xcerpt Number: 63
Comment: The Proposed Rule revises §98.233(o) and (p), the emissions calculation sections for compressors. Compared to the current emission estimation paradigm, these proposed revisions improve rule organization and clarity, and correct and improve calculations and ties to the reporting sections. INGAA supports these revisions. However, additional corrections, clarifications, and edits are needed. These include:

• Verification and clarification of the intent and implementation of the text in §98.233(p)(6)(iii)(B) (section 98.233(p)(7)(i)(A) in the current rule) is needed:

• "You must combine emissions for blowndown vents, measured in the operating and standby

pressurized modes." This requirement to combine blowdown valve leakage emissions from the two compressor modes is not consistent with the rule equations and the current reporting requirements of the e

GGRT Excel reporting form. Equation W

- 28 is used to calculate an emission factor for each compressor mode

- source combination specified i n §§98.233(p)(1)(i)(A)

- (C):

• Operating mode

- rod packing,

• O perating mode

- blowdown valve leakage,

• Standby

- pressurized

- mode

- blowdown valve leakage, and

• Not

- operating

- depressurized

- mode

- isolation valve leakage. Calculation of emission factors for each mode is r equired by §98.233(p)(1)(iii). In addition, separate operating mode

- blowdown valve leakage and standby

- pressurized

- mode

- blowdown valve leakage emission factors are needed because it is unlikely that annual blowdown valve leakage emissions would be measured in both the operating

- and standby

- pressurized

- modes.

112Separate emission factors are needed to estimate emissions in the unmeasured mode(s). For example, if the annual measurements for a compressor were conducted in the operating mode, then Equation W

- 26 w ould be used to calculate measured emissions for operating mode

blowdown valve leakage and Equation W

- 27 would be used to calculate unmeasured emissions for standby

- pressurized

- mode

- blowdown valve leakage. Combining the emissions would eliminate the two se parate emission factors. Either the intent and use of this text should be explained and clarified, or this text should be deleted. Response: The EPA has evaluated the commenter’s concerns and agrees that the proposed provision in §98.233(p)(6)(iii)(B) is incorrect and should be deleted. In the final rule, we have revised §98.233(p)(6)(iii) to state that the emission factors must be calculated annually and we have deleted proposed § 98.233(p)(6)(iii)(A) and (B).

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: The associated reporting sections for centrifugal and reciprocating compressors, §§9 8.236(o) and (p), report emissions from "emission vents" which trace back to "compressor sources," "compressors," and associated operating modes and measurement data. INGAA recommends that these sections be reviewed and "beta tested" to ensure the source(s ), and associated compressor(s) operation and measurements for all reported emissions are clearly understood, and are consistent with data collected and emissions calculated by the equations in §98.233(o) and (p). With limited time to prepare these comment s and schedule overlap with 2013 GHGRP reporting, time was not available to complete such a detailed review. Response: The EPA thanks the commenter for their input. We agree with the commenter that the reporting requirements should be consistent with the calculation requirements finalized in this rule

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: API also supports clarification that the count of compressors is the total number of centrifugal compressors that have wet seal oil degassing vents, as this removes confusion over screw compressors and rotary vane compressors.

113Response: The EPA thanks the commenter for the ir support. These revisions are finalized as proposed.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: Switch the order of 98.233(o)(6)(ii) and 98.233(o)(6)(iii). Switch the numbering of Equations W

- 22 and W

- 23: One cannot perform the calculation in (ii) without first performing the calculation in (iii). W

- 22 depends on W

- 23. This illogical reverse order is highly confusing for reporters who are first reading the rule. This is a relic of the original Subpart W, and EPA should take this opportunity of expansive revisions to fix this. These same changes should be made for 98.233(p)(o)(6)(ii) and 98.233(p)(o)(6)(iii) and for Eq uations W

- 27 and W

- 28. Response: The EPA has evaluated the commenter’s concerns and has determined the rule does not need to be revised. The order of equations in the final rule is logical from a top down perspective. A reporter is first shown the primary equation (i.e., Equation W

- 22) for calculating annual volumetric CH 4 or CO 2 emissions for unmeasured compressor mode

- source combinations; and in order to properly use this Equation W

- 22, the variable “EF s,m ” must be determined by using Equation W

- 23. This same top down perspective is used for Equations W

27 and W

- 28. No change has been made to the final rule as a result of this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Contr ol Number: EPA

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Comment: The subscript order is inconsistent in Equations W

- 22, W

- 23, W

- 27 and W

- 28. All of the other compressor equation subscripts use the subscript "s" as the lead with exception of t he terms EFm,s and MTm,p,s in Equations W

- 22, W

- 23, W

- 27 and W

- 28. These should be revised to EFs,m and MTs,m,p for consistency with the other compressor equations. Response: The EPA agrees with the commenter’s suggested edits and has subsequently revised the rule.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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114Comment: Add a subscript "s" to the term MT g,avg in Equations W

- 24B and W

- 29B : All other volumetric emission terms at standard conditions lead with an "s" subscript. This term should be changed to MT s,g,avg for consistency. Response: The EPA agrees with the commenter’s suggested edits and has revised t he final rule accordingly

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Commenter Name: Jeff Applekamp Commenter Affiliation: Document Control Number: EPA

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Comment: Inappropriate use of the word "leak" in all centrifugal compressor and recipr ocating compressor sections: Throughout sections 98.233(o), 98.233(p), 98.236(o) and 98.236(p), EPA inappropriately uses the word "leak" to refer to all compressor emission sources. This is incorrect, and both sections need to be extensively revised to del ete this word or replace it with "vent" or "leak or vent". While it is appropriate to characterize emissions associated with isolation valves and blowdown vent valves as "leaks", wet seal oil degassing emissions and rod packing emissions occur by design an d are definitely not leaks. It is appropriate to characterize these as emission sources as "vents". Response: The EPA has evaluated the commenter’s concerns and agrees that the use of the word "leak" to refer to all compressor emission sources is inaccura te . The final rule has been revised such that the word “leak” is either replaced with the term “leak or vent” or simply deleted (as when used in the phrase “leak measurements” because t he term “measurements” is sufficient and more accurate)

.

Commenter Na me: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: 98.236(o)(2) and 98.236(p)(2) language is confused on whether it contains reporting requirements for compressor sources or for emission vents. Both sections muddle requirements for both. As the requirements are currently structured, it appears one would report all the elements of 98.236(o)(2) for each compressor source including all the e mission vent information in 98.236(o)(2)(iv), 98.236(o)(2)(v), 98.236(o)(2)(vi), 98.236(o)(2)(vii), and 98.236(o)(2)(viii). So, for example, if there are five compressor sources manifolded to one emissions vent, the information in 98.236(o)(2)(iv), 98.236( o)(2)(v), 98.236(o)(2)(vi), 98.236(o)(2)(vii), and 98.236(o)(2)(viii) would be reported five times. This is a waste of time and resources. 98.236(o)(2) should contain compressor source reporting elements only (i.e., 98.236(o)(2)(i) through (iii)). Then a n ew section 98.236(o)(3) should contain emission vent reporting elements only (i.e., 98.236(o)(2)(iii) through (viii)). The unique name or ID for the emission vent

115(98.236(o)(2)(iii)) will tie the information together, just as the compressor name or ID ties the information in 98.236(o)(1) and (2) together. This comment and suggested correction also applies to the analogous requirements in 98.236(p). Response: The EPA has evaluated the commenter’s concerns and has revised the final rule such that the reporti ng requirements at § 98.236(o)(2) and § 98.236(p)(2) more clearly differentiate between data elements required for each compr essor source at each compressor and data elements required for each leak or vent.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: EPA should reconsider new reporting requirements. Numerous data elements have been ar bitrarily added, are not needed to calculate GHG emissions, and will add unnecessary burden for reporters. The Proposed Rule significantly increases the number of data elements to report under §98.236. Although the preamble includes confidentiality determ inations, and a docket memo tabulates the changes, EPA has not explained or justified the need for these data elements. As discussed in Comment 9, the new reporting requirements increase costs, and EPA should justify its decision for each data element adde d to §98.236. If INGAA understood EPA’s objective for adding the data elements, it is possible that specific feedback on various data elements could be provided. A partial list of data elements added for T&S sources that should be reconsidered and justifie d if included follows:

• Compressor power rating

– §98.236(o)(1)(xiii), §98.236(p)(1)(xiii);

• Year compressor was installed

– §98.236(o)(1)(xiv), §98.236(p)(1)(xiv);

• Compressor model name and description

– §98.236(o)(1)(xv), §98.236(p)(1)(xv);

• Date of last ma intenance shutdown that compressor was depressurized

– §98.236(o)(2)(viii);

• Date of last maintenance shutdown for rod packing replacement

– §98.236(p)(1)(xvi);

• If emission vent is routed to flare, combustion, or vapor recovery, report the percentage of tim e the device was operational

– §98.236(o)(2)(viii), §98.236(p)(2)(viii);

• Whether compressor was measured in operating mode or not

- operating depressurized mode

– §98.236(o)(1)(iv);

• Whether compressor sources are routed to a flare

– §98.236(o)(1)(vii), §98.2 36(p)(1)(ix);

• Whether compressor sources have vapor recovery

– §98.236(o)(1)(viii), §98.236(p)(1)(x);

116• Whether compressor sources are captured for fuel use or are routed to a thermal oxidizer

– §98.236(o)(1)(ix), §98.236(p)(1)(xi);

• Whether compressor has blind flanges installed

– §98.236(o)(1)(x), §98.236(p)(1)(xii);

• Whether compressor is part of a manifolded group of compressor sources

– §98.236(p)(1)(viii); Several specific examples are discussed further to demonstrate INGAA questions and concerns:

• Compr essor power rating (hp);

• Year compressor was installed;

• Compressor model name and description;

• Date of last maintenance shutdown where centrifugal compressor was depressurized. INGAA questions the utility of these four parameters / data points for purposes of the GHGRP inventory. For example, compressor driver horsepower is very likely a poor indicator of potential GHG emissions since GHG emissions are largely dependent on compressor run time and other factors rather than power rating. Also, regulatory defi nitions are not consistent and actual working horsepower could be significantly less than site rated horsepower or manufacturer nameplate horsepower. The need for these data is unclear, and there is no indication that these parameters could be used to pred ict potential GHG emissions based on compressor type or horsepower. In addition, the preamble and background documents do not provide justification for adding all of these elements, or consider the costs or benefits. If there are certain objectives EPA is trying to achieve by increasing reporting burden, the objectives should be explained and decisions should be justified. INGAA would welcome the opportunity to discuss the utility of various data elements further. For these examples, while general compresso r information (model, installation date, date of last maintenance shutdown) could be compiled, this information is superfluous to the GHG inventory. In addition, EPA should review its determination of whether these data are CBI (see Comment 20). Response: The EPA has evaluated the commenter’s concerns

. T he additional reporting requirements included in th e proposed r ule provide production, capacity, and operational information that are useful for the verification of existing data. However, we have revised t he reporting requirements based on our review of the comments received and have removed the reporting requirements for the year the compressor was installed and the model name and description of the compressor. We also revis ed the proposed “compressor powe r rating” element to clarify that this reporting element is the “power output of the compressor drive r ”

. We have also re placed the reporting requirement for the date of the last maintenance shutdown with a simple indication of whether the compressor had a scheduled depressurized shutdown during the reporting year. See Section II.E.2 of the preamble to the final rule for additional response to this comment.

117Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: b) 98.236(o)(1) (xiv) ; 98.236(p)(1)(xiv) "Year compressor was installed." It’s unclear exactly what information EPA is seeking, but installation year is not a clear or necess arily informative piece of information as compressors are routinely moved from one facility to another. For example, a compressor that was originally manufactured in 1980 could be relocated and installed at a Subpart W reporting facility in 2014. Further, until recently when NSPS OOOO was proposed, operators had no need to track year of installation, manufacture, reconstruction, etc. of their compressors. Even now, operators only need to determine whether a compressor was in

- service, in stock, or ordered pr ior to 8/23/2011, not the specific year of installation. Therefore, the "year of installation" data may not be readily available, if it is available at all. This data element is not required to calculate greenhouse gas emissions and will require time consu ming research to provide. This reporting element should be removed. c) 98.236(o)(1)(xv) and 98.236(p)(1)(xv) "Compressor model name and description." The term "description" is too vague. EPA needs to consider how e

- GGRT will be programmed and clearly speci fy what information is to be reported for both "model name" and "description". This requirement should either be removed or revised to "Compressor manufacturer and model identification." d) "98.236(o)(1) (xvi) Date of last maintenance shutdown that compress or was depressurized." This data element and the analogous 98.236(p)(1)(xvi) must be deleted. This is completely unrelated to greenhouse gas emissions. If EPA seeks information on compressor maintenance activities, it should do so under another means. Also , this question is vague. If a compressor automatically shuts down on an unscheduled basis due to a mechanical issue, and maintenance is performed on the compressor, would this be considered a "maintenance shutdown"? Some reporters will interpret that it i s a "maintenance shutdown", while others will not, and thus the information generated here will be misleading at best. Response: See response to comment EPA

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Commenter Name: Thomas J. Bach Commenter Affiliation: Ki nder Morgan Energy Partners, L.P Document Control Number: EPA

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Comment: With respect to the Agency’s proposed reporting requirements, Kinder Morgan specifically supports the comments of API and INGAA. A s API notes, man y of the data elements that EPA requests in the Proposed Rule under § 98.236 are not required for calculation of GHG emissions (e.g., compressor power rating, year compressor was installed, and dates of last maintenance shutdown that compre ssor was depressurized 21 ).

118Footnotes:

21 See proposed § 98.236(p)(xiii), (xiv) and (xvi). Response: See response to comment EPA

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Commenter Name: Carrie B. Crumpton Commenter Affiliation: CONSOL Energy, Inc. Document Control Number: EPA

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Comment: The rule itself incorporates data collection and reporting requirements that go beyond the requirements of a reporting program. This includes:

• Various compressor sp ecifications not currently required for reporting which includes power ratings, model details, year of installation, model name and description, and date of last maintenance shutdown for centrifugal and reciprocating compressors. Response: See response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Re ference for Centrifugal Compressors: §98.236(o)(1)(xiii), Proposed Rule Text: Compressor power rating (hp). API objects to reporting this information as it is does not reflect the emission efficiency or performance for well

- maintained equipment. In additio n, the terminology is not correct. Compressors do not have hp ratings, engines do. Compressors can be powered by electric motors, which also would not have a hp rating. Response: See response to comment EPA

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Commente r Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 127

119Comment: Proposed Citation Reference for Reciprocating Compressors: §98.236(p)(1)(xiii), P roposed Rule Text: Compressor power rating (hp). API objects to reporting this information as it is does not reflect the emission efficiency or performance for well

- maintained equipment. In addition, the terminology is not correct. Compressors do not have hp ratings, engines do. Compressors can be powered by electric motors, which also would not have a hp rating. Response: See response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Centrifugal Compressors: §98.236(o)(1)(xiv), Proposed Rule Text: Year compressor was installed. API obje cts to reporting this information as it is does not reflect the emission efficiency or performance for well

- maintained equipment. In addition, the install year may not be available for every compressor. If EPA insists on requiring this information, compani es will need to be able to use an estimate or best available information. Response: See response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Reciprocating Compressors: §98.236(p)(1)(xiv), Proposed Rule Text: §98.236(p)(1)(xiv) Year compressor was installed. API objects to reporti ng this information as it is does not reflect the emission efficiency or performance for well

- maintained equipment. In addition, the install year may not be available for every compressor. If EPA insists on requiring this information, companies will need t o be able to use an estimate or best available information. Response: See response to comment EPA

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120Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EP A

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Comment: Proposed Citation Reference for Centrifugal Compressors:§98.236(o)(1)(xv), Proposed Rule Text: Compressor model name and description. API objects to reporting this information as it is does not reflect the emission efficiency or performance for well

- maintained equipment. It is also unclear what information would be reported for “description”. Response: See response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 129
Comment: Proposed Citation Reference for Reciprocating Compressors: §98.236(p)(1)(xv), Proposed Rule Tex t: Compressor model name and description API objects to reporting this information as it is does not reflect the emission efficiency or performance for well

- maintained equipment. It is also unclear what information would be reported for “description ”.
Res ponse: See response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 125
Comment : Proposed Citation Reference for Centrifugal Compressors:§98.236(o)(1)(xvi), Proposed Rule Text: Date of last maintenance shutdown that compressor was depressurized. API objects to reporting this information as it is does not reflect the emission efficie ncy or performance for well

- maintained equipment. If EPA insists on requiring this information, companies will need to be able to use an estimate or best available information

. Response: See response to comment EPA

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121Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Reciprocating Compressors: §98.236(p)( 1)(xvi), Proposed Rule Text: Date of last maintenance shutdown for rod packing replacement API objects to reporting this information as it is does not reflect the emission efficiency or performance for well

- maintained equipment. If EPA insists on requirin g this information, companies will need to be able to use an estimate or best available information. Response: See response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Ins titute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Reciprocating Compressors:§98.236(p)(2)(viii), Proposed Rule Text: If the emission vent is routed to flare, combusti on, or vapor recovery, report the percentage of time that the respective device was operational. This information is extremely difficult to collect for every compressor. Reporters will need to have the option to use engineering estimates based on available information. Response: This reporting element is being retained in the final rule. The EPA clarifies in this response that this reporting requirement is not intended to add additional monitoring or measurement requirements. The percentage of time the dev ice was operational may be determined using engineering estimates based on best available information.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: h) 98.236(o)(2)(viii) and 98.236(p)(2)(viii) "If the emission vent is routed to flare, combustion, or vapor recovery, report the percentage of time that the respective device was operational." Depending on the vapor recovery configuration, defining operational time is challenging. For example, if the compressor is only operating 50% of the year and the vapor recovery is therefore also only operating 50% of the year, what would be reported here? If 50% is reported, EPA may inco rrectly assume that half of the vapors are not being captured. Also, the percent of time that "fuel gas" is "operational" doesn’t necessarily make sense. EPA should

122consult with technical experts to reword this requirement appropriately, or simply eliminat e the requirement, as it appears to have no relevance to GHG emission reporting. If EPA wants to assess emissions not captured, then they should require this to be reported directly using engineering judgment; a "percentage of time" requirement does not pr ovide any useful emission data for EPA. Response: We have clarified this requirement to be “ If the leak or vent is routed to flare, combustion, or vapor recovery, report the percentage of time that the respective device was operational when the compressor source emissions were routed to the device

. ” The EPA clarifies in this response that this reporting requirement is not intended to add additional monitoring or measurement requirements. The percentage of time the device was operational may be determined using engineering estimates based on best avai lable information

.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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Comment: Proposed EPA Amendment: Among other additional data elements being r equested for centrifugal and reciprocating compressors in 40 CFR 98.236 (o) and (p), EPA is seeking the following information:

• Compressor power rating (hp);

• Year compressor was installed;

• Compressor model name and description;

• Date of last maintenance shut down that compressor was depressurized. Williams questions the utility of the requested data for purposes of the GHG inventory. Compressor engine or motor horsepower is a poor indicator of potential GHG emissions since such emissions are largely dependent on compressor run time, not power rating. Also, actual working horsepower could be significantly less than rated horsepower. Thus, the likelihood of accurately predicting potential GHG emissions for a compressor based on compressor type and horsepower woul d be low. While general compressor information (model, installation date, date of last maintenance shutdown) is available, we view this information as unnecessary to the GHG inventory program. In addition, we view this data to be confidential business info rmation (CBI). Response: See response to comment EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA)

123Document Control Number: EPA

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Comment: Suggested edits to §98.236(p)(1): (viii) Indicate whether which, if any , compressor sources are part of a manifolded group of compressor sources. (ix) Indicate whether which, if any , compressor sources are routed to a flare. (x) Indicate whether which, if any , compressor sources have vapor recovery. (xi) Indicate whether which, if any , emissions from any compressor sources emissions are captured for fuel use or are routed to a thermal oxidizer. (xii) Indicate whether th e compressor has blind flanges installed

. and associated dates.

• §98.236(p) states that the information in §98.236(p)(2) applies to all reciprocating compressors at a facility. However, §98.236(p)(2)(vii) is for reporting methane and CO2 emissions, and the se requirements would not apply for compressors that vent all gas to a flare, VRU or combustion unit.

• Suggested edits to §98.236(p)(2): (iii) Unique name or ID for the emission vent. If the emission vent is connected to a manifolded group of compressor sou rces, use the same emission vent ID for each compressor source in the manifold group

.

• Suggested edits to §98.236(p)(3)(i): (B) Sample Measurement date. (E) For each compressor attached to the emission vent, report the compressor operating mode during the m easurement of operation the compressor was in when the sample was taken. Response: Except as discussed further in this paragraph, the EPA agrees with the commenter’s suggested edits and has subsequently revised the rule accordingly . EPA has also made anal ogous revisions to § 98.236(o). The commenter suggests using the phrase “compressor operating mode” in § 98.236(p)(3)(i)(e); however, the EPA disagrees with the use of the word “operating” in this phrase and has instead revised the phrasing to “compressor mo de” because this term is defined in the final rule.

Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Company (SoCal Gas) Document Control Number: EPA

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124Comment: §98.236(p)(1)(iii) of the Proposed Rule incorrectly asks for reciprocating hours in the "standby

- depressurized" mode. The three modes of operation are operating, standby pressurized and not

- operating

- depressurized. Therefore, §98.236(p)(1)(iii) should say:

• (iii) Hours in standby

- de pressurized

- mode. Similarly, §98.236(p) (l)(vi) should say:

• (vi) Indicate whether the compressor was measured in standby

- de pressurized

- mode Response: The EPA agrees with the commenter’s suggested edits and has subsequently revi sed the rule.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: 98.236(o)(1)(xiii) and 98.236(p)(1)(xiii) "Compressor power rating (hp)." It is unclear if EPA is truly requesting the power rating of the compressor or the power rating of the driver (e.g., engine, turbine, electric motor). The compressor power is limited by the driver power. For the driver, "power rating" is a h istorically complex term, as "rating" can be interpreted a number of different ways. For example, does this account for site conditions such as altitude? EPA should consult with technical experts to clearly and specifically distinguish what data is being r equested and why it is being requested. GPA is not aware of evidence to suggest that the horsepower rating of compressor driver is an indicator of emissions from that compressor. Response: In an effort to minimize interpretation, the EPA has revised the r equirements in § 98.236(o)(1)(xiii) and § 98.236(p)(1)(xiii) in the final rule to specify the “power output of the compressor driver (hp)”.

Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Company (SoCal Gas) Document Co ntrol Number: EPA

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Comment: It is assumed that the new activity data to be reported (i.e. dates of last maintenance shutdown) is associated with the new language for Mode 3 testing. The rule language will require new tracking systems to be implemented to be able to report accurately regardless of whether a mode 3 measurement has been taken or is needed to be taken to meet the 3 year criteria. This places another burden on the operator without any impac t toward the reporting of actual or estimated emissions. Perhaps the intent of the data acquisition could be met by

125modifying the wording to "Date of last Mode 3 Measurement" or only submitting the dates if deferred measurements are made: 98.236(o)(1)(xvi) Date of last maintenance shutdown that compressor was depressurized if a shutdown depressurized mode measurement was not taken at least once in any 3 consecutive years. 98.236{p)(l)(xvi) Date of last maintenance shutdown for rod packing replacement if a shutdown depressurized mode measurement was not taken at least once in any 3 consecutive years

. Response: The EPA has replaced the reporting requirement for the date of the last maintenance shutdown with a simple indication of whether the compressor had a scheduled depressurized shutdown during the reporting year . This indication, reported each year, will provide the data needed by the EPA while minimizing the burden to the reporter

.

Commenter Name: Karin Ritter Commenter Affiliation: American Pe troleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Centrifugal Compressors: §98.236(o)(2)(viii), Proposed Rule Text: If the emission vent is routed to flare, combustion, or vapor recovery, report the percentage of time that the respective device was operational. This information is extremely difficult to collect for every compressor. Reporters will need to have the option to use engineering estimates based on available information. Response: We have clarified this requirement to be “ If the leak or vent is routed to flare, combustion, or vapor recovery, report the percentage of time that the respective device was operational when the compressor source emissions were routed to the device. The EPA clarifies in this response that this reporting requirement is not intended to add additional monitoring or measurement requirements. The percentage of time the device was operational may be determined using engineering e stimates based on best available information

.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: e) 98.236(o)(2) and 98.236(p)(2) apply to all compressors, including compressors that have compressor sources routed to fuel, thermal oxidation, or vapor recovery. These types of compressor sources do not have to report emissions. However, 98.236(o)(2)(vii) and 98.236(p)(2)(v ii) require emissions to be reported; these requirements should be moved to

126another section, or be made not

- applicable for compressor sources routed to fuel, thermal oxidation, or vapor recovery. Response: The EPA has evaluated the commenter’s concerns an d has revised the final rul e such that the requirements proposed at § 98.236(o)(2) (vii) and (p)(2)(vii) do not apply to compressor sources routed to flare, combustion, or vapor recovery . The EPA notes that these requirement s are now in §98.236(o)(2)(ii)(D) and (p)(2)(ii)(D)

.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: i) 98.236 (o)(3)(ii)(D) and 98.236(p)(3)(ii)(D) shoul d be revised to eliminate the term "corporate" which is not defined in Subpart A or Subpart W and is not generally used in the reporting rule. (D) Indicate whether the compressor mode

- source combination reporter emission factor is facility
- specific or corp orate based on all of the reporter’s applicable facilities

. Response: The EPA agrees with the commenter’s suggested edits and has subsequently revised the rule.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: Blowdown volumes could skew continuous measurement results: 98.233(o)(3)(ii), 98.233(o)(5)(iii), 98.233(p)(3)(ii) and 98.233(p)(5)(iii) state, "If compressor blowdo wn emissions are included in the metered emissions... the compressor blowdown emissions may be included with the reported emissions for the... compressor source(s)." This reduces burden on reporters, but EPA needs to include a new reporting element to indicate whether such measurements include blowdown volumes. These blowdown volumes could have the potential to substantially skew compressor vent emission data which could lead to uninformed data interpretation and/or emission factors. 98.236(o)(4)(iii) Indicate whether the measured volume included blowdown emissions

. 98.236(p)(4)(iii) Indicate whether the measured volume included blowdown emissions

.

127Response: The EPA agrees with the commenter that a reporting element is needed to indicate whether continuous me asurements include blowdown volumes. The final rule is revised to include this data element at § 98.236(o)(4)(iii) and (p)(4)(iii). 

### 15.7 Comments on emission factor approach for compressors

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Ga s Association of America (INGAA) Document Control Number: EPA

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Comment: Alternative approaches that build on INGAA members commitment to measurement : Based on our experience and technical expertise gaine d from implementing ongoing GHG programs, previous INGAA comments recommended a programmatic approach for reporting and T&S inventory improvement where focused data collection and measurement would address primary data gaps. For example, INGAA recommended conducting high quality measurement over the initial years of the program to fill data gaps. Analysis of that data could provide a path to improved alternative methods for ongoing emission estimates. In addition, INGAA has consistently requested equitable requirements for data collection and reporting for the natural gas industry, including T&S sources. Other industrial sectors subject to the GHGRP are generally allowed to estimate emissions rather than being required to conduct physical measurements. Other industries are allowed to use emission factors, engineering estimates, measurements already conducted for other purposes or generally available (e.g., fuel measurement), or minimal or simplistic additional measurements. In contrast, T&S and other natural gas segments are required to complete annual measurements and surveys of numerous process vents whose primary purpose is to safely vent gas away from personnel and equipment. Measurement or monitoring of vented emissions from these numerous vent lines has not previously been required for other EPA regulatory or emission inventory purposes. Consequently, Subpart W has required implementation of equipment modifications and the development of new practices and systems for these operations

– e.g., for T&S, this includes installation of measurement ports and development of procedures to sample compressor valve and rod packing leakage, and implement facility

- wide leak surveys that require screening of inaccessible components. While its members abided by EPA’s requirement to complete measurements for Subpart W, INGAA has consistently recommended a process to collect quality data, and use that data to develop emission factors or other streamlined estimation methods for emissions from compressor vents and equipmen t leaks. INGAA recommendations are based on the fundamental premise that emission factors, engineering estimates, and related estimation methods are the longstanding technical approach to emission inventory development and are consistent with the requireme nts for other industries subject to the GHGRP. Subpart W measurements completed to date provide a voluminous data set in comparison to the amount of data typically available for developing emission factors that are used for inventory development

– includin g emission factors used for other GHGRP industrial sectors.

128INGAA strongly believes that future Subpart W inventories for the T&S segments should be developed by leveraging the numerous data already collected, identifying and filling data gaps, and develop ing a reasonable engineering estimate approach based on these data (e.g., emission factors), and retiring the annual measurement requirement after a reasonable timeframe. INGAA members have consistently indicated and exhibited a willingness to complete mea surements and to assist in development of new emission factors for the T&S sector. Since 2009, Subpart W measurements from the T&S sector have produced an extensive data set of methane emissions from compressors, process vents, and other sources in multipl e operating modes. Data from 2011 and 2012 reporting are publicly available, and significant additional measurement data will be available from 2013 and 2014 reporting. INGAA members have completed thousands of measurements in 2011 to 2013 and reported associated emissions to fulfill Subpart W requirements. For the 2011 and 2012 reports currently available (2013 reporting was completed by March 31, 2014), INGAA member companies reported:

• For T&S reciprocating compressors, more than 5,000 measurements of compressor valve and rod packing leakage from over 1,400 affected compressors across the three compressor modes in Subpart W (i.e., operating, standby pressurized, and not operating, depressurized). Similar numbers of measurements were completed in each mo de.

• For T&S centrifugal compressors, nearly 1,000 measurements from more than 475 compressors across the two modes in Subpart W (i.e., operating and not operating, depressurized).

• For 2011 and 2012, INGAA member companies have collectively conducted over 6 00 facility leak surveys, with a resulting conservative estimate of over a million components screened for leaks. With 2013 activities recently reported and 2014 testing underway, data from these two years will approximately double the available reported d ata. Thus, a considerable and substantial data set is available for review and analysis. The Proposed Rule essentially continues with the status quo rather than assessing the significant resource available from these thousands of measurements, making corre ction where warranted, and devising a plan to utilize the measured data to develop alternatives to ongoing annual measurement. Response: See Section II.B.11 of the preamble to the final rule for the EPA’s response to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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129Comment: EPA arbitrarily requires more rigorous and higher cost approaches for the natural gas industry, including transmission and storage sources, than for other industries subject to the GHGRP. INGAA has consistently questioned EPA’s decision to require ongoing annual measurement for the natural gas industry, including T&S sources, while ot her industries and sources are allowed to use standard inventory approaches such as emission factors and engineering estimates, or straightforward measurements that are generally already conducted for other purposes. GHGRP requirements and the associated b urdens for natural gas T&S facilities subject to Subpart W are disproportional to those of other covered industries with a similar magnitude of GHG/methane emissions. By requiring T&S direct measurements, the Proposed Rule treats similarly

- situated entitie s differently without a reasoned explanation and substantial evidence in the record. Natural gas T&S facilities have a multitude of new and complex data collection and reporting requirements for the GHGRP that include significant new measurement requiremen ts for vent lines that have historically not been measured for any purpose and were not designed or constructed with measurement access considered. Requirements include:

• Annual (or more frequent) facility

- wide equipment leak surveys;

• Annual (or more freque nt) transmission storage tank surveys and measurements;

• Tracking and recording of compressor mode and annual leakage / vent measurements for reciprocating and centrifugal compressors at affected T&S facilities. In many cases, these new measurement requirem ents have required installation of sample ports, and vent line modifications or man

- lift rental for safe access;

• On

- going blowdown event tracking (type, location, frequency, volume, temperature, and pressure) following procedures that may differ from exist ing practices;

• Collection of combustion equipment emissions data for Subpart C;

• Emission calculations and reporting for the multiple emission sources;

• Annual population counts of gas driven pneumatic devices and storage wellhead components; and

• Setup, ongo ing maintenance, and populating the recordkeeping systems used to compile and retain the thousands of data elements and measurements. INGAA reviewed requirements for other industries, and Landfills and Underground Coal Mining (two of the industries address ed by the White House "Climate Action Plan") have similar magnitudes of methane emissions as natural gas systems, and sources within these industries have annual methane emissions similar in magnitude to compressors from T&S and gas processing. However, wh ile gas processing and T&S require annual compressor measurement, the other industries have much simpler and less burdensome GHGRP requirements. Table 1 compares methane emissions based on EPA’s 2012 draft U.S. GHG Inventory6, i.e., estimates are based on the EPA U.S. GHG Inventory report; Subpart W estimates are considerably lower for compressor related emissions.

130Table 1. U.S. GHG Inventory Methane Emission Estimates for Natural Gas Systems, Landfills, and Coal Mining.
GHG emissions for Landfills are cov ered by Subpart HH (MSW Landfills) and Subpart TT (Industrial Landfills). Emissions are predominately from MSW landfills (i.e., about 95%), and the methane emission estimation methods are similar for both subparts. The mass of waste deposited in the landfi ll each year is determined and the volume of methane generated is estimated using a carbonaceous waste decay model. The volume of methane emitted to the atmosphere is calculated by adjusting the modeled emissions for methane oxidation by soil using a facto r and the volume of methane destroyed by gas collection and combustion systems. Data collection requirements include:

• Mass of waste loads deposited in the landfill by mass scales or counts of vehicles and containers and capacity estimates. It is expected t his is an ongoing activity (i.e., pre

- dates the GHGRP) for billing and / or other purposes; and

• Volume of methane destroyed by gas collection and combustion systems by monitoring collected landfill gas flowrate and collecting samples to determine landfill gas methane concentration. This could be a new requirement for the GHGRP or could be an ongoing activity for operations, regulatory, or other purposes. Summary data collected by the GHGRP for 2012 7 indicate that over 50% of the MSW landfills do not report combustion emissions under Subpart C and it is assumed these landfills do not have gas collection and combustion systems. Thus, it appears that over 50% of the MSW landfill facilities were not requ ired to collect additional (i.e., new) data for the GHGRP, and the remaining facilities only have a single new data collection requirement. GHG emissions for Underground Coal Mines are covered by Subpart FF and two emission sources are covered: ventilation systems which include ventilation shafts or vent holes where mine ventilation air is emitted; and, degasification systems which include degasification wells and gob gas vent holes deployed before, during, or after mining operations are conducted.

• Data col lection requirements for ventilation systems include quarterly measurements of CH 4 emissions. Results of the quarterly (or more frequent) testing performed by the Mine Safety and Health Administration (MSHA) for methane flowrate may be used for the GHGRP. This is an ongoing activity (i.e., pre

- dates the GHGRP) and appears to add minimal burden to the facilities.

• Data collection requirements for degasification systems include weekly measurements of CH 4 emissions. This could be a new requirement for the GHGRP or could be an ongoing activity for operations, regulatory, or other purposes. Thus, it appears that additional data collection requirements for the GHGRP for underground coal mine facilities is limited to a single new emission source. Contrasting these l imited new GHGRP data collection requirements for landfills and underground coal mines (i.e., single new emission source or sink for each industry) with the multitude of new and complex GHGRP measurements and data collection requirements for the many emiss ion sources at T&S facilities, it is apparent that the burden for T&S facilities is much

131greater and disproportionate to the magnitude of GHG emissions. INGAA members have collected thousands of data points to date for the first three years of reporting, a nd it is reasonable to expect that data gaps associated with inventory development should be addressed and measurement burden should decrease over time.
Footnotes:

7 http://www.epa.gov/climate/ghgreporting/ghgdata/2012data.html Response: See Section II.B. 11 of the preamble to the final rule for the EPA’s response to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: EPA should review the existing Subpart W measurement data available for reciprocating and centrifugal compressors for T&S sources in 2011 and 2012. For reciprocating compressors, the reported compressor

- mode data indicates that similar counts of measured data are being acquired in each of the three modes (i.e., operating; standby pressurized; not operating, depressurized or shutdown). Data from the first two years indicates an adequate number of measurements are being completed in each mode. This includes over a thousand reciprocating compressor measurements for each mode

- source combination; hundreds of centrifugal compressor measurements for both isolation valve (shutdown mode) and blowdown valve (operating mode) leakage; and, nearly tw o hundred measurements of wet seal oil degassing vents. This data also indicates that there are far fewer centrifugal compressors with wet seals than previously estimated by EPA; thus estimated emissions from centrifugal compressors wet seal degassing are likely much lower than current estimates in EPA’s U.S. GHG Inventory. As noted above, INGAA members have completed thousands of measurements in 2011 to 2013 and reported associated emissions in response to Subpart W requirements. Additional detail is provi ded for 2011 and 2012 measurements. INGAA member companies reported more than 5,000 measurements from over 1,400 affected reciprocating compressors in the T&S sector across the three modes with a similar number of measurements in each of the three modes. D uring the same period, member companies reported nearly 1,000 measurements from more than 475 centrifugal compressors across two modes (i.e., operating and shutdown). GHGRP 2013 reporting was completed by March 31, 2014, and is expected to increase the num ber of measurements by about 50% . Coupled with 2014 measurements currently underway, the number of reported measurements publicly available will approximately double. An initial review of these data records indicates modal tests provide operators the abil ity to calculate reporter specific emission factors. Thus, a substantial data set is currently, and will remain, available for analysis. These GHGRP Subpart W measurements could be significantly augmented with a myriad of additional existing

132data from a va riety of sources. These sources include: earlier GRI EPA sponsored studies; GRI Canada, Canadian Association of Petroleum Producers (CAPP) and Petroleum Technology Alliance Canada (PTAC) sponsored studies; 2011 University of Texas Natural Gas Industry Meth ane Emission Factor Improvement Study; and T&S data that will become available from a current industry

– EDF project being conducted by Colorado State University. Other than a desire to continue with the status quo, the need for mandating mode

- specific tes ts has not been explained or justified. The provisions requiring shutdown mode measurements on a defined frequency should be eliminated. Response: See Section II.B.11 of the preamble to the final rule for the EPA’s response to this comment.

Commenter Na me: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: The Proposed Rule essentially continues the current measurement program while adding additional restrictions. INGAA understood EPA’s desire in the original 2010 final rule to gather additional measured data to address data gaps for key sources. With thousands of measurements already completed, it is unclear how or if EPA has used that data in developing the Proposed Rule. A path should be defined for data analysis, development of alternative emission estimation methods, and elimination or substantial reduction of the burden of ongoing annual measurements. Response: See Sectio n II.B.11 of the preamble to the final rule for the EPA’s response to this comment.

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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Comment: As INGAA is requesting, Kinder Morgan notes that it would be interested in having further discussions with EPA about the development of accurate emission factors to replace the multitude of physical measurements currently required by Subpart W. Reporting entities under all other Subparts of Part 98 may use emission factors in lieu of costly and burdensome physical measurements and Kinder Morgan believes that there has been enough data gathered under Subpart W for accurate emission factors to be similarly incorporated into Subpart W. Response: See Section II.B.11 of the preamble to the final rule for the EPA’s response to this comment.

133Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

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Comment: The Future Use of Emission Factors. The proposal does not consider alternatives to annual measurement, such as the use of emission factors for compressor vents, which EPA has discu ssed with industry trade associations. During these discussions, EPA indicated a willingness to develop emission factors for compressor vents and other sources in lieu of direct measurement, however, the proposal is silent on this important point. This is most critical for compressor vents. Compressor vents are the most problematic sources to measure for the reasons discussed above, namely that they are required to be measured in one of three operating modes over a three year period and vents are sometimes manifolded so that measurements of individual compressors is not possible. EPA's proposals to alleviate these issues provide only a partial remedy. The use of good, accurate emission factors would more accurately reflect emissions over the year, rather tha n annualizing a snapshot measurement that may be flawed. We encourage EPA to continue discussions with the trade groups on this important issue with a specific goal of revision to the rule to reflect those discussions by the end of 2015. Response: See Section II.B.11 of the preamble to the final rule for the EPA’s response to this comment.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Fugitive emission measurements for compressors are expensive and EPA is collecting significant measurement data through Subpart W. API strongly encourages EPA to move from annual measurement of compressor emissions toward an emission factor approach using the measurement data they have received. Response: See Section II.B.11 of the preamble to the final rule for the EPA’s response to this comment.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Con trol Number: EPA

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134Comment: Williams also suggests that EPA consider the use of company

- wide emission factors for compressor vents routed to flare, and for compressor vents routed to atmosphere that are i naccessible. Williams also requests that EPA consider industry

- wide emission factors for compressors, in lieu of these measurements. Response: See Section II.B.11 of the preamble to the final rule for the EPA’s response to this comment.

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

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Comment: We specifically support amendments that will provide for the use of emission factors that are well researched and based on current operating standards and reflect the recently enacted New Source Performance Standards for the natural gas industry. (40 C.F.R. Part 60 Subpart 0000). As discussed in the recently issued White House Climate Action P lan: Strategy to Reduce Methane Emissions, the need for a sound understanding of methane emissions from the natural gas industry is critical to ensuring that the benefits of natural gas are supported by transparent, complete, and accurate reporting. We are a partner in the natural gas transmission and storage study of the NGO

- industry cooperative research initiative sponsored by the Environmental Defense Fund and supports this type of initiative to close the gaps in our understanding of methane emissions. F uture amendments should incorporate new understandings of emissions as they evolve. Response: See Section II.B.11 of the preamble to the final rule for the EPA’s response to this comment. 

### 15.8 Other comments on issues not proposed related to centrifugal and
re ciprocating compressors

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Because it appears EPA has failed t o assess and scrutinize data collected to date, INGAA is very concerned that the Proposed Rule would retain flawed Subpart W requirements and fail to achieve the objective of an improved GHG emission estimate for T&S sources. Instead, a likely outcome is a dditional years of measurement and continued inventory uncertainty and questions about data gaps. Thus, the technical and policy objectives of the GHGRP will not be achieved. This outcome would also fail to fulfill the following key objectives in the recen tly released White House methane strategy 5 : improving methane measurement (e.g., addressing areas of significant emissions and higher uncertainty in bottom up inventories, such as

135compressors); promoting a common understanding of methane emissions from nat ural gas systems and related abatement opportunities; and, identifying downstream emission reduction opportunities (e.g., develop strategies for cost

- effectively reducing methane emissions from natural gas processing, transmission and storage, LNG, and dis tribution).
F ootnotes :

5 "Climate Action Plan

– Strategy to Reduce Methane Emissions." White House (March 2014). http://www.whitehouse.gov/sites/default/files/strategy_to_reduce_methane_emissions_2014

- 03

- 28_final.pdf Response: The EPA disagrees with the c ommenter that the proposed rule fails to achieve the policy objectives of the GHGRP. As noted in the preamble to the April 10, 2009 proposed rule (74 FR 16448), the goal of the GHGRP is to collect data of sufficient accuracy and quality to inform future CA A policy development. Through data collected under this rule, the EPA is able to review the relative emissions of specific industry segments and sources, and the distribution of emissions from individual facilities within those industries and sources . This facility

- specific data also improves understanding of the factors that influence GHG emission rates and actions that facilities are alrea dy taking to reduce emissions. As noted in the preamble to the April 10, 2009 proposed rule (74 FR 16448), the goal of the GHGRP is to collect data of sufficient accuracy and quality to inform future policy development. For these same reasons, the EPA disagrees with the commenter that the proposed rule would fail to achieve the objectives outlined in the White House Clim ate Action Plan

- Strategy to Reduce Methane Emissions (hereinafter "the Strategy"). In fact, the strategy specifically mentions the proposed revisions to subpart W and notes that they would enhance the clarity and consistency of the reported data from pet roleum and natural gas systems. The strategy notes the need for the EPA to continue to review regulatory requirements to address potential gaps in coverage, improve methods, and help ensure high quality data reporting.

Commenter Name: Lisa Beal Comment er Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Data quality objectives (DQOs) and inventory uncertainty targets are not defined and are nee ded to rationally guide data collection requirements and develop a reliable inventory. Rule design, implementation, and end results (i.e., a reliable inventory consistent with GHGRP objectives) would greatly benefit from definition of and consistent adher ence to DQOs for inventory uncertainty and completeness (e.g., first determine inventory uncertainty and completeness objectives and then design data collection to achieve these objectives). For compressor valve leakage and vent gas measurements, Subpart W has an apparent completeness objective of 100% for both the number of subject compressors tested and measurement of one or more vents associated with the "as found" operating mode for each compressor. INGAA

136comments since 2009 have documented many barrier s to this objective (e.g., safe access to vent lines, technical feasibility), and alternatives to the "all vents" target (i.e., 100% measured) have been offered. Instead of considering alternatives, in an attempt to achieve "100% completeness," EPA adopted an indirect method (see Comment 13 on the acoustic method) and still labored with the BAMM request and approval process over the first four years of Subpart W reporting. The Proposed Rule would eliminate BAMM in 2015 and the measurement program would cont inue unabated. A cursory review of 2011 and 2012 data indicates that Subpart W compressor methane emissions are substantially lower than the estimate from the annual U.S. GHG Inventory. The relative count of facilities (and compressors) that report under S ubpart W versus the count in the national inventory does not account for all of the difference. Several contributing factors could be hypothesized, including whether Subpart W measurements were completed using a direct or indirect measurement method. Howev er, the Proposed Rule does not introduce a systematic approach to reconcile these differences, other than additional years of data collection (i.e., annual measurements) and requiring several additional data elements to be reported. In addition to exacerba ting the current confusion regarding the "real" methane emissions attributable to T&S operations, failure to reconcile these differences in a timely manner does not comport with the White House methane strategy. INGAA strongly believes a much more efficien t and effective approach could be designed and implemented that would provide improved and more complete results much quicker and at lower cost

. The inferred DQO of "measuring 100% of compressor vented emissions" is overly burdensome and unrealistic. EPA has made other decisions regarding covered compressor operating mode

source combinations, sources included, estimation methods prescribed, etc., that do not appear to consistently follow defined objectives. Several examples where INGAA has raised questions about inventory uncertainty due to methods used, compressor modes tested, and emission factor flexibility are identified in Comment 14. Based on background provided in Comment 13, the record indicates that the 100% completeness objective for vent measurem ent is not achievable without some combination of unsafe work practices, inordinate costs (e.g., substantial redesign and re

- plumbing on inaccessible vent lines, exhuming buried valves), and non

- standard and indirect measurement methods. A more rational ap proach would be to set a completeness objective for "valid data" that considers the population of compressors and compressor vent lines that can be safely and efficiently tested. This population can be determined from emissions data, measurement records, B AMM requests for 2011

– 2013, and additional communications with affected stakeholders. The representativeness of this "accessible" population can be considered against the total compressor population. Additional actions, such as screening inaccessible ven ts using an IR camera, can further document the status of vents where emission rate cannot be measured. This would allow the universal and consistent use of standard direct measurement test methods. Such an approach could target an inventory uncertainty objective(s) that will result in a better understanding of emission sources and a data set suitable for its intended use (e.g., fill data gaps to improve GHG estimates and inform future policy). Continuing to burden operators with

137questionable measurements serves no useful purpose

– and alternatives are available. INGAA welcomes the opportunity to discuss this topic further. Response: See response to comment EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Inter state Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 31
Comment: INGAA’s technical recommendations since 2009 provide approaches more likely to achieve GHGRP objectives than the S ubpart W annual measurement mandate. Review and analysis of measurement data collected to date are recommended to assess lessons learned and to determine whether there are programmatic corrections that should be considered to improve data quality and achie ve program goals. Entering the fourth year of Subpart W implementation, questions remain about Subpart W methane estimates and the associated methane T&S inventory in comparison to historical data and other papers and analysis, including the annual EPA U. S. GHG Inventory. There is an abundance of recent papers and publications exploring methane estimates from natural gas systems

– with a common thread of disparate estimates and conclusions regarding methane losses from T&S and other segments. With three ye ars of Subpart W measurements complete and a fourth underway, INGAA believes that a well

- designed program could have filled T&S data gaps and resolved uncertainties associated with source

- level estimates and a bottom up inventory. In that regard, Subpart W has failed to meet GHGRP objectives and EPA has failed to meet its obligation to develop a robust program. If uninformed, one may conclude that the use of alternatives (e.g., prevalence of BAMM) is a root cause. However, T&S operators have demonstrated a willingness to complete measurements, as evidenced by the thousands of measured data results in 2011 and 2012 reports. Additionally, many operators who used BAMM did so as a means to address rule inconsistencies, to ensure the ability to comply as EPA cont inued to revise and amend Subpart W, and to address a subset of inaccessible vents. INGAA does not believe that the Proposed Rule provides a clear and efficient pathway to resolve the issues encountered to date, and the significant resources committed to a nnual measurements at hundreds of facilities will be for naught

– or at best will require too many additional years of measurements and too much time to understand the Subpart W data implications. As a result, Subpart W will be marginalized

– or deemed inc onsequential or unreliable

– by other, more effective measurement programs and/or research. This does not have to be the script that is followed. In its 2009 and 2010 comments, INGAA strongly recommended a programmatic approach to address data gaps and imp rove emission estimation, and INGAA believes that an alternative Subpart W program could have (and should have) been designed and implemented. INGAA strongly recommends reconsideration of the current path and revisiting the design and intent of measurement requirements for T&S sources. Subpart W measurements could fill data gaps, be

138used to develop improved emission factors and estimation methods, reduce emission estimate uncertainties, and meet EPA regulatory and policy objectives. These objectives are con sistent with the objectives in the White House methane strategy released in March 2014. As currently implemented and as amended in the Proposed Rule, INGAA believes that Subpart W will either fail to meet these objectives for T&S sources, or will only arri ve at conclusions after many additional, unnecessary years of annual measurement.
INGAA is not re

- hashing previous recommendations in these comments, but refers EPA to previous comments

– especially 2009 and 2010 comments, as well as other communications a nd programs that have been discussed in meetings since GHGRP inception. INGAA would welcome the opportunity to engage EPA in additional discussions on this topic and complementary projects. Response: See response to comment EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 73
Comment: INGAA and its members remain committed to proj ects that improve T&S GHG emission estimates. INGAA would welcome cooperative efforts with EPA. Comment 1 reviews a partial list of INGAA and natural gas industry activities over the last two decades related to improving the understanding of GHG emissions from our operations, including many projects with EPA. These efforts continue, and an ongoing industry project could provide an opportunity to leverage Subpart W data and support the development of alternatives to current Subpart W requirements.
INGAA and the Pipeline Research Council International (PRCI, a pipeline collaborative research group) are collecting supplemental data from their members to provide additional insight into 2011 and 2012 Subpart W measurements. Analysis is planned that may provide in sight into measurement method uncertainties. That program also plans to collect 2013 Subpart W data and supplemental data from members, and assess whether that data facilitates a better understanding of data quality and emissions for key Subpart W sources

– especially compressors. The project is not prejudging the likelihood of success, and insights from data analysis will define the path forward. For example, the project may consider options such as:

• Segments covered will include transmission and storage, but could be expanded to include other segments (e.g., gas processing) where Subpart W measurement is required.

• Sources will focus on compressors and each of the compressor mode

– emission source combinations defined in Subpart W. The project may also asse ss equipment leak survey results (e.g., prevalence of leaks by component type and service) and the frequency and volume of transmission condensate tank dump valve leakage.

139• Data analysis will include the data elements submitted for Subpart W via the e

- GGRT reporting form as well as supplemental data collected on operations, equipment, and measurement methods. Data review may indicate the need to revisit the supplemental data request and add more data elements

– e.g., to address questions regarding test metho ds used and categorize measured data based on the measurement method used.

• Based on information collected to date, it appears that approximately 75% or more of the T&S facilities that are required to report per the GHGRP are INGAA and/or PRCI members shari ng data for this project. At this time, the project does not plan to analyze publicly available data from other facilities, but quality control checks will likely be conducted to compare reported emissions for facilities within the INGAA/PRCI dataset to ot her facilities that reported. Similarly, data from other segments could be added by collaboration with third parties that facilitate access to supplemental data or other measurement reports.

• Following compilation and initial data analysis, the status will be discussed with INGAA and PRCI advisors to consider questions such as data representativeness and data quality. As appropriate, follow

- up steps will be initiated and a determination will be made regarding whether: (1) analysis to initiate emission factor development is feasible, and/or (2) additional data and information is needed to facilitate emission factor development.

• If emission factor development is pursued, various approaches for segregating the data into different subsets will be considered based on equipment or operational characteristics, and other factors and alternatives that affect emission factor quality and emission estimation uncertainty. This could include consideration of approaches that include periodic tests or additional data gatherin g in an effort to continue to refine estimates or ensure uncertainty targets are met and maintained. Potential approaches will be vetted with INGAA/PRCI project advisors. INGAA has offered alternative approaches in previous comments, but these are the firs t comments submitted since the project with PRCI was initiated. INGAA believes it is imperative that we learn from the measurements being completed and the INGAA/PRCI project is intended to address that objective. At this time, it is unclear what type of a nalysis EPA has undertaken or plans for future efforts. INGAA welcomes the opportunity to discuss this further with EPA, and cooperatively define a path to utilize the thousands of measurements completed and continuing in 2014, including assessing whether programmatic changes should be considered to ensure data quality. INGAA is very concerned that the Proposed Rule appears to continue the annual measurement mandate without reviewing measurement data collected to date, assessing lessons learned from three y ears or measurement and reporting, or determining whether there are programmatic corrections that should be considered at this time to improve data quality. Response: The EPA appreciates the commenter's continued commitment to participating in the rulemaking process and providing input to help inform and improve the requirements of subpart W and the EPA is willing to consider an emission factor approach under Part 98 for compressors. The EPA agrees that facilities have collected data under part 98 r elated to centrifugal and reciprocating compressors that can be used to inform an emission factor. However, the data which are inputs to emissions equations have not yet been reported to the EPA because they are deferred for reporting until 2015. The defer red reporting elements include the reporter

- specific emission factors that are used to calculate emissions and the total time that a compressor is in a

140particular mode. The reporter

- specific emission factors provide information on how measured data is appl ied to a reporter’s other compressors that were not measured in a particular mode, and these factors are applied to all compressors for the total time each compressor is operated in each mode. Therefore the deferred data provide important information that could help inform the development of emission factors for each mode of operation. The EPA intends to analyze this deferred information after it is received in 2015. In addition, the data that will be reported under these final rule amendments will provide additional data that can inform the development of emission factors, such as information on the power output of the compressor driver. Furthermore, the compressor revisions that are being finalized in this rule will improve the quality of the reported data and address technical issues received from stakeholders during program implementation. The EPA is committed to working with stakeholders to review regulatory requirements, methods, and the quality of the information reported. The EPA looks forward to rev iewing the deferred Part 98 data, data that will be reported under these revisions and data from outside studies in order to determine if appropriate emission factors can be developed, and, if so, the EPA may revise the calculation and reporting requiremen ts for compressors in a future rulemaking. See response to comment EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: INGAA has repeatedly raised questions on inventory completeness and accuracy tha t have not been specifically answered or were dismissed. In some cases, this may be detrimental to achieving GHGRP objectives. For example:

• INGAA raised questions about excluded sources that may be worth considering (e.g., source

mode related emissions for compressors that are not included);

• INGAA requested an alternative method that would allow operators to use optical imaging to qualitatively assess leakage through a vent that cannot be accessed for measurement;

• INGAA asked for the ability to use higher q uality data for combustion methane

– i.e., more accurate exhaust methane emission factors for reciprocating engines estimates under Subpart C so that this methane source is more accurately reported. If a comprehensive programmatic approach is considered fo r updating Subpart W requirements, INGAA would also be interested in additional discussions regarding those previous EPA decisions. In summary, INGAA remains committed to improving GHG estimates from T&S sources and would welcome a cooperative effort with EPA to address data gaps, improve GHG estimates, and address GHGRP objectives.

141Response: The EPA notes that the issues addressed by the commenter have been responded to in previous rulemakings. In this final rule, the EPA has reviewed the optical gas imag ing methods in § 98.234(a) and determined that these methods are appropriate for pre

- screening for leakage from compressor vents. The final rule allows the use the methods in § 98.234(a) for pre

screening of emissions from isolation valves, blowdown valves, or rod packing released through a vent, provided that sources conduct follow

- up measurements if leaks are detected. See Section II.B.11 of the preamble to the final rule for additional information.

Commenter Name: Lisa Beal Commenter Affiliation: Inter state Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Comparable use of the IR camera and acoustic instrument for screening purposes. When vent measurement is required, Subpart W includes methods for detecting or pre

- screening for leaks prior to measuring the vented emission rate, such as screening a transmission condensate tank dump valve for leakage. §98.234(a)(5) allows the use of an acoustic instrument to check for l eakage, and vent emission rate measurement is not required if leakage through the valve is not detected. Although the rule text is not completely clear, this approach also appears to be allowed for leakage from compressor isolation valves in §98.233(o) and (p). Use of acoustic instruments for detecting leakage through valves was requested by INGAA and others in June 2010 comments and added to Subpart W. Similarly, Subpart W allows optical imaging (i.e., "IR camera") for leak surveys required in 98.233(q) and for screening transmission condensate tank vented emissions from dump valve leakage in §98.233(k). INGAA has recommended that the IR camera also be allowed for screening other vents that require measurement. It is not clear why EPA selectively applies IR camera or acoustic instrument screening for some applications but not others, and this decision has never been explained or justified. INGAA recommends the flexibility to allow use of the IR camera for this purpose whenever vent measurement is required. Similar to using an acoustic instrument to detect leaks across dump valves or isolation valves, or using the IR camera to screen for dump valve leakage through tank vents, the IR camera can be used to screen for leaks from compressor isolation valves, blo wdown valves, or rod packing released through a vent and identify whether vent measurement is needed. This is especially important for screening vents that are unsafe or impractical to access. INGAA understands that several companies have received approval of BAMM requests to use the IR camera to screen these compressor sources for emissions. The use of the IR camera should not be unnecessarily restricted, and inconsistencies regarding methods (i.e., acoustic instrument or IR camera) and applications (e.g., dump valve, isolation valve, blowdown valve) in Subpart W have never been explained or justified by EPA. In fact, INGAA expected the Proposed Rule to include revisions to §98.233(o) and (p) to allow the use of the IR camera method in §98.234(a)(1) for com pressor vent screening. INGAA recommends revisions to the Final Rule to address this issue. Response: The EPA has considered these comments and has included in the final rule provi sions to allow for the use of optical gas imaging equipment for compressor vent screening.

142We are finalizing provisions in § 98.233(o)(2)(i)(D) and § 98.233(p)(2)(i)(D) to allow the use of the methods in § 98.234(a) to allow for pre

- screening for leaks from compressor isolation valves, blowdown valves, or rod packing released throug h a vent. Reporters may use this method to identify whether further vent measurement is needed. If any emissions are detected, then reporters are required to use one of the methods currently specified in subpart W (acoustic leak detection device, calibrate d bagging or high volume sampler, or temporary meter such as a vane anemometer) to quantify emissions. If no emissions are detected, the reporter would be allowed to use zero as the measured emissions rate and would not be required to follow

- up with a meas urement to further quantify emissions. See Section II.B.11 of the preamble to the final rule for additional information responding to this comment.

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Contro l Number: EPA

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Comment: EPA Should Clarify that Subpart W Does Not Require a Leakage Measurement Where Leak Screening Indicates that No Leakage Is Present. Where Subpart W calls for the quantification of GHG emission leakage, it is unclear and inconsistent about when pre

- screening for leaks can be used as a means to determine whether an actual leakage measurement is necessary or not. Section 98.233(k) provides an example that should be replicated througho ut Subpart W. Section 98.233(k) requires that the annual emissions of a storage tank leak be quantified. However, § 98.233(k)(2) expressly states that such leak must be quantified only if it is first identified through one of several leak screening methods . Under § 98.233(k), if leak detection determines that no leak is present, then a leak quantification is not required. However, many other parts of Subpart W are silent about whether leakage measurement is required if leak pre

- screening indicates that a le ak is not present. For instance, § 98.233(o)(1) simply requires a reporting entity to "[m]easure emissions from all vents" annually including "blowdown valve leakage through the blowdown vent" for centrifugal compressors

– without stating whether pre

- scree ns indicating that no leakage is present might excuse the requirement to carry out the measurement process. Subpart W is similarly silent on whether leak screening indicating that no leakage is present can be used to excuse leakage measurement from rod pac king and blowdown vents of reciprocating compressors under § 98.233(p)(1). Wherever Subpart W contemplates the measurement or quantification of leakage, Kinder Morgan requests that EPA clarify that no further leak measurement or quantification is necessary if leak screening technology indicates that no leak is present. Response: In the final rule, we have clarified in §98.233(o)(2)(i)(D) and (p)(2)(i)(D) that if no emissions are detected, the reporter would be allowed to use zero as the measured emissions rate and would not be required to follow

- up with a measurement to further quantify emissions

.

143Commenter Name: Kelly Guertin Commenter Affiliation: DTE Energy Document Control Number: EPA

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Comment: The Proposed Rule arbitrarily excludes viable measurement methods. DTE recommends measurement flexibility. Since the original rule proposal in 2009, DTE in association with INGAA has consistently requested measurement method flexibility that allows the us e of viable technologies and methods for detecting leaks and for vent or leak rate measurement. The 2010 Subpart W final rule and subsequent amendments have accommodated some of the requests and significantly improved the rule. However, examples remain whe re EPA has excluded viable methods or included unnecessarily prescriptive criteria. DTE recommends measurement method flexibility when feasible. DTE wholeheartedly endorses comments submitted by INGAA with regards to measurement flexibility ["Comments on t he Proposed Amendments to Subpart W of the Greenhouse Gas Mandatory Reporting Rule" Submitted by Interstate Natural Gas Association of America (INGAA) (April 24, 2014).] Response: The EPA has corrected the measurement methods in the final rule to allow fo r the use of an acoustic leak detection device; additionally, the EPA is allowing for the use of optical gas imaging equipment for pre

- screening of emissions from isolation valves, blowdown valves, or rod packing released through a vent. These revisions pr ovide measurement flexibility for reporters and ensure that reporters are able to complete measurements and comply with subpart W requirements. See Section II.B.11 of the preamble to the final rule for additional information responding to this comment

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: EPA should ma ke provision in §98.233 (o) to include seal

- oil/gas separation and recovery as a vapor recovery unit (VRU) for purposes of measurement of emissions from seal

- oil degassing systems (vents). These systems are equivalent to the ones reported into EPA’s Natural Gas Star program by BP and others. API suggest s the followin g edit to §98.233(o)(1)(i) (A) to accomplish this goal : 98.233 (o) (1) (i) (A) For a compressor measured in operating

- mode, you must measure volumetric emissions from blowdown valve leakage through the blowdown vent as specified in either paragraph (o)(2)(i) (A) or (o)(2)(i)(B) of this section and, if the compressor has wet seal oil degassing vents, measure volumetric emissions from wet seal oil degassing vents as specified in paragraph (o)(2)(ii) of this section. If a compressor has a continuously operating v apor recovery system for the wet seal degassing, then measurement of wet seal degassing is not required.

14498.233 (o)(1)(A) (1) For purposes of this Subpart, a system of seal
- oil and gas separation with recovery of separated gas is considered to be a vapor recovery system. Response: The EPA has evaluated the commenter’s concerns and agrees that the seal

- oil/gas separation and recovery is a vapor recovery. The introductory text in §98.233(o) states that “If emissions from a compressor source are routed to v apor recovery, paragraphs (o)(1) through (o)(12) of this section do not apply.” Based on this provision, we find that the last sentence proposed at §98.233(o)(1)(i)(A) to be redundant. If vapors in the wet seal oil are separated and recovered, then the wet seal oil degassing vent compressor source emissions are recovered and there are no measurement or calculation requirements for that compressor source. We are deleting the last sentence proposed at §98.233(o)(1)(i)(A)

.


### 16.0 Leak Detection Equipment and Emission s from Components
16.1 Revisions to § 98.233(q) and (r) and calculation of facility meter/regulator run emission factor Commenter Name: Pamela Lacey Commenter Affiliation: American Gas Association (AGA) Document Control Number: EPA

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Comment: One of AGA’s key remaining concerns with the Subpart W rule was the confusion generated by the inconsistent use of "meter runs" or individual "components" as the basis for developing emission factors for natural gas dist ribution facilities. Our member natural gas distribution companies were unsure about what the rule required. And they were concerned that the inconsistent language in the rule might be interpreted to require counting individual components, including not on ly the few found to be leaking but millions of non

- leaking components, which would have imposed tremendous reporting burdens without any offsetting benefit. We are very pleased that this was not EPA’s intent, and that EPA now proposes to make that clear by placing the meter/regulator run emission factor calculation to section 98.233(q) instead of 98.233(r), and clarifying that the emission factor is calculated separately for CO 2 and CH 4 and is based on a meter

- regulator run rather than the individual compon ents within a run. Response: The EPA thanks the commenter for their support. The revisions clarifying that the emission calculations are based on meter/regulator runs are finalized as proposed. 

### 16.2 Calculation of emissions from above grade transmission
- distr ibution (T
- D) transfer stations.

Commenter Name: Bert Kalisch Commenter Affiliation: American Public Gas Association Document Control Number: EPA

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145Comment: Minimum Reporting Required to Estimate GHG from Above Grade Transmission

Distribution Transfer Stations and Other Above Grade Metering Regulating Stations In addition, EPA’s rule requires utilities to conduct leakage surveys at transmission/distribution t ransfer stations ("TD transfer stations") and calculate component

- specific emissions estimates using Equations W

- 30, W

- 31 and W

- 32B: EQ W

- 30:
E s,p,i = EF s,p * GHG i * Sum(T p,z )
Where:
E s,p,i = Annual total volumetric emissions of GHGi from specific componen t type "p" in standard ("s") cubic feet.

x p = Total number of specific component type "p" detected as leaking during annual leak surveys. EF s,p = Leaker emission factor for specific component types listed in Table W

– 7 of this subpart.
GHG i = For natural ga s distribution, GHG i equals 1 for CH4 and 1.1 × 10
- 2 CO2.
T p,z = The total time the surveyed component "z", component type "p", was found leaking and operational, in hours. EPA could calculate the annual total volumetric emissions of GHGi from specific com ponent type "p" using Equation W

- 30 if operators submitted the following: 1. Total number of specific component type detected as leaking during annual leak surveys and 2. Total time the surveyed component types were found leaking and operational.
The result of Equation W

- 30 is used in Equation W

- 31 to calculate an emission factor for meter/regulator runs. EQ W

- 31
EF s,MR,i = Double sum(E s,p,i,y ) / Double sum(T w,y )
Where:
EF s,MR,i = Meter/regulator run population emission factor for GHGi based on all surveyed above grade transmission distribution transfer stations over "n" years, in standard cubic feet of GHGi per operational hour of all meter/regulator runs.
E s,p,i,y = Annual tota l volumetric emissions at standard conditions of GHGi from component type "p" during year "y" in standard ("s") cubic feet, as calculated using Equation W

– 30.

146p = Seven component types listed in Table W

– 7 for transmission distribution transfer stations.
T w ,y = The total time the surveyed meter/ regulator run "w" was operational, in hours during survey year "y."
Count MR,y = Count of meter/regulator runs surveyed at above grade transmission distribution transfer stations in year ‘"y". y = Year of data include d in emission factor "EF s,MR,i ." n = Number of years of data used to calculate emission factor "EF s,MR,i ". EPA could calculate the meter/regulator run population emission factor "EF s,MR,i " for the distribution system using Equation W

- 31 if operators submit ted the following: 1. Total time the surveyed meter/ regulator run was operational during survey year, 2. Count of meter/regulator runs surveyed at above grade transmission distribution transfer stations in the year of data included in emission and the num ber of years of data used to calculate emission factor "EF s,MR,i ". The result of Equation W

- 30 is used in Equation W

- 32B to calculate annual volumetric emissions of GHG i . EQ W

- 32B
E s,MR,i = Count MR * EF s,MR,i * T w,avg Where:
E s,MR,i = Annual volumetric emi ssions of GHGi from all meter/regulator runs at above grade metering regulating stations that are not above grade transmission distribution transfer stations, in standard cubic feet.
Count MR = Total number of meter/regulator runs at above grade metering

- re gulating stations that are not above grade transmission

- distribution transfer stations.
EF s,MR,i = Meter/regulator run population emission factor for GHGi based on all surveyed above grade transmission distribution transfer stations over "n" years, in stan dard cubic feet of GHGi per operational hour of all meter/regulator runs., as determined in Equation W

– 31.
T w,avg = Average estimated time that each meter/regulator run was operational in the calendar year, in hours per meter/ regulator run.
EPA could calc ulate the annual volumetric emissions of GHGi from all meter/regulator runs at above grade metering regulating stations that are not above grade transmission distribution transfer stations using Equation W

- 32B if operators submitted the following:

1471. Total number of meter/regulator runs at above grade metering

- regulating stations that are not above grade transmission

- distribution transfer stations and 2. Average estimated time that each meter/regulator run was operational in the calendar year. Everything fr om this point on relies on equations and fixed factors specified in the rule with no further information needed from the responder. EPA could calculate GHG mass emissions in metric tons by converting the GHG volumetric emissions estimated using Equations W

- 32 A & B into estimated mass emissions using Equation W

– 36. EQ W

- 36
Mass i = E s,i * p i * 10 - 3
Where:
Mass i = GHG i mass emissions in metric tons.
E s,i = GHGi volumetric emissions at standard conditions, in cubic feet, calculated using Equations W

- 32 A&B

p i = Density of GHGi. EPA should modify its e

- GGRT program to collect only the 12 data elements listed above from natural gas distribution operators reporting under Subpart W. These data are sufficient to allow e
- GGRT to calculate volumetric, metric tons and metric ton CO2e without any additional input from the responding distribution operator. E

- GGRT should alert the reporting entity whether the data entered results in estimated emissions at or above the 25,000 metric ton CO2e reporting threshold. Response: The EPA disagrees with the commenter that the above data elements are the only data elements that should be collected from natural gas distribution operations

. It is our practice to allow reporters to override emissions calculated by the e

- GGRT system. In order to do that, the emissions (or emission factors), must be reporting elements. We have reviewed the required reporting elements and have determined that the proposed reporting elements are useful and necessary for the purpose of emissions reporting an d verification of the reported data. Therefore, the EPA is finalizing these reporting requirements as proposed, with minor clarifications. With respect to the request that the e

- GGRT system alert the reporting entity whether the data entered results in es timated emissions at or above the 25,000 metric ton CO 2 e reporting threshold , this request is beyond the scope of this rulemaking. However , per the requirements set forth in §98.2(i), reporters may need to continue to report for a certain period of time if their emissions are less than 25,000 metric tons CO 2 e and they exceeded the reporting threshold in a previous reporting year

. Given these requirements, we are concerned that providing a simple alert at the 25,000 metric ton CO 2 e threshold might be misinterpreted to suggest an annual report is not required , when in fact the report may still be required to be submitted.

148Commenter Name: Pamela Lacey Commenter Affiliation: American Gas Association (AGA) Document Control Number: EPA

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Comment: Clarify Calculation of Emissions Over Multiple Year Cycle: Under the Subpart W Proposed Revisions, annual equipment leak surveys would be conducted at above grade transmission

- distribution (T

- D) transfer stati ons according to §98.233(q). Section 98.233(q)(8)(i) allows all distribution facility above

- grade T

- D transfer stations to be surveyed over multiple years up to a five year cycle. It appears that the emission calculation requirements of §98.233(q) and the emission reporting requirements of §98.236(q)(2) only apply to equipment leaks at the above grade T

- D transfer stations surveyed during the reporting year. Emissions for equipment leaks at the above grade T

- D transfer stations not surveyed during the repor ting year are not calculated or reported. AGA suggests revising the associated text and equations so that these emissions could be calculated using Equation W

- 32B and the emission factors calculated using Equation W

- 31. Response: The EPA agrees with the c ommenter and is revising the final rule to clarify that emissions from equipment leaks at above grade transmission

- distribution stations not surveyed during the reporting year are to be calculated using Equation W

- 32B (which uses the emissions factor calcu lated using Equation W

- 31) , as suggested by the commenter

. See Section II.B.11 of the preamble to the final rule for additional discussion respon ding to this comment. 

### 16.3 Calculation of emissions from below grade Emissions from belo w grade metering regulating sta tion s , below grade transmission
- distrib ution transfer stations, distrib ution mains, and distrib ution services.

Commenter Name: Bert Kalisch Commenter Affiliation: American Public Gas Association Document Control Number: EPA

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- 0074

- A1 C omment Excerpt Number: 2
Comment: Minimum Reporting Required to Estimate GHG from Mains, Service Lines and Below Grade Metering Regulating & Transmission

- Distribution Transfer Stations Estimated GHG emissions from below grade metering regulating station s, below grade transmission

- distribution transfer stations, distribution mains, and distribution services are calculated using Equation W

– 32A of 40 CFR 98.233(r): EQ W

- 32A Es,e,i = Count e * EF s,e * GHG i * T e Where:

149E s,e,i = Annual volumetric emissions of G HGi from the emission source type in standard cubic feet. The emission source type may be a component (e.g. connector, open

- ended line, etc.), below grade metering

- regulating station, below grade transmission

- distribution transfer station, distribution mai n, or distribution service.
Count e = Total number of the emission source type at the facility. Natural gas distribution facilities must count: (1) The number of distribution services by material type; (2) miles of distribution mains by material type; and ( 3) number of below grade metering

- regulating stations, by pressure type; as listed in Table W

– 7.
EF s,e = Population emission factor for the specific emission source type, as listed in Table W

– 7.
GHG i = 1 for CH4 and 1.1 × 10
- 2 CO2.
T e = Average estimated ti me that each emission source type associated with the equipment leak emission was operational in the calendar year, in hours, using engineering estimate based on best available data. EPA could calculate the metric tons of GHGs using Equation W

- 32A and othe r equations in the rule if operators submitted the following: 1. Number of distribution services by material type; 2. Miles of distribution mains by material type; 3. Number of below grade metering

- regulating stations, by pressure type;
4. The number of below grade transmission

- distribution transfer stations and 5. Average estimated time that each emission source type associated with the equipment leak emission was operational in the calendar year. Everything from this point on is calculated using equations and factors mandated by EPA. From that data, EPA can calculate estimated emissions from these sources, so requiring the reporting operators to perform those calculations is an unnecessary reporting burden increases the likelihood of calculation e rrors that would reduce the value of the resulting data. Response: See response to comment EPA

- HQ

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- 0074

- A1, Excerpt 3 in Section 16. 2 of this document. 

### 16.4 Comments on applicable definitions and other minor revisions and restructuring of reportin g requirements for leak detection and emissions from components.

Commenter Name: Bert Kalisch Commenter Affiliation: American Public Gas Association

150Document Control Number: EPA

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- A1 Comment Excerpt Number: 1
Comment: APGA commends EPA for proposing to simplify the reporting. APGA encourages EPA to even further simplify reporting by natural gas distribution operators by limiting reporting to only those data that are necessary for EPA to calculate estimated Greenhouse Gas ("GHG") emi ssions. EPA could and should further reduce the number of calculations reporting distribution operators need to perform

. Specifically, EPA should modify the regulation and it’s electronic Greenhouse Gas Reporting Tool ("e

- GGRT") to require natural gas dist ribution operators reporting under Subpart W to report only the following: 1. The number of distribution services by material type; 2. Miles of distribution mains by material type; 3. The number of below grade metering

- regulating stations, by pressure type ; 4. The number of below grade transmission

- distribution transfer stations; 5. Average estimated time that each emission source type associated with the equipment leak emission was operational in the calendar year; 6. The total number of specific component type detected as leaking during annual leak surveys of above grade transmission/distribution transfer stations; 7. The total time the surveyed component types, were found leaking and operational; 8. The total time the surveyed meter/ regulator run was ope rational during survey year; 9. The count of meter/regulator runs surveyed at above grade transmission distribution transfer stations; 10. The number of years of data used to calculate emission factor; 11. The total number of meter/regulator runs at above grade metering

- regulating stations that are not above grade transmission

- distribution transfer stations; and 12. The average estimated time that each meter/regulator run was operational in the calendar year. From these data EPA can calculate the estimated metr ic tons of GHG emissions from natural gas distribution system operators. Reducing the number of calculations EPA requires responders to perform would ease reporting burdens and improve the quality of the data by reducing the potential for calculation e rrors.

151Even though EPA is proposing to no longer require natural gas distribution operators to convert metric tons of individual GHGs into CO2e, APGA notes that these operators must still determine if their estimated GHG emissions exceed the reporting thre shold of 25,0000 in metric tons CO2e. This conversion should be performed by e

- GGRT and e

- GGRT should alert the reporting entity if the results of calculations using the 12 data elements listed above result in estimated GHG emissions at or above the report ing threshold of 25,000 metric tons CO2e. APGA commends EPA for proposing to simplify the reporting of estimated greenhouse gas emission under Subpart W. The Subpart W regulations are extremely complex and confusing. Public gas utility managers have made b est efforts to comply with EPA’s reporting requirements but still report difficulty understanding the equations and calculation methods. EPA should reduce reporting burdens and increase the accuracy of its data by limiting reporting to only those data nece ssary for EPA to calculate estimated GHG emissions. Response: See response to comment EPA

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- A1, Excerpt 3 in Section 16. 2 of this document

.

Commenter Name: Pamela Lacey Commenter Affiliation: American Gas Association (AGA) Document Control Number: EPA

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- 0083

- A1 Comment Excerpt Number: 3
Comment: Clarify Section 98.236(r) Applicability: Section 98.236(r)(1) does not apply to equipment leaks at above grade metering

- regulating stations that are not above grade transmi ssion

- distribution transfer stations, but this may not be sufficiently clear based on the proposed text. This should be clarified by revising the text in §98.236(r) or §98.236(r)(1). In addition, EPA should make it clear that section 98.236(r)(1) would not apply to equipment leaks at the above grade T

- D transfer stations not surveyed during the reporting year. Response: The EPA agrees with the commenter that the current reporting requirements may potentially be unclear. We have clarified the applicability of the reporting requirements of § 98.236(r)(1) to be specific to emission source types required to use Equation W

- 32A. Only natural gas distribution facilities with above grade metering

- regulating stations that are not above grade transmission

- distribution transfer stations are required to report under § 98.236(r)(2).

Commenter Name: Pamela Lacey Commenter Affiliation: American Gas Association (AGA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 4
Comment: AGA recommends the use of consistent nomenclature and terminology throughout the data collection sections [§§98.233(q) and (r)] and reporting sections [§§98.236(q) and (r)].

152For example, the units for the meter/regulator run emission factor (EFs,MR,i) in Equations W

- 31 and W

- 32B are "standard cubic feet of GHGi per operational hour of all meter/regulator runs"; however, different terminology is used in the associated reporting section. The following are suggested clarifying edits to ensure that the rule uses consistent t erminology. We have identified our suggested additional text in bold underline text and suggested deletions in strikethrough text. "§ 98.236 Data reporting requirements.

... (q) Equipment leak surveys.

... (3) Natural gas distribution facilities must report th e information specified in paragraphs (q)(3)(i) through (q)(3)(viii) of this subpart.

... (vii) Meter/regulator run CO 2 emission factor based on all surveyed transmission

- distribution transfer stations in the current leak survey cycle, in standard cubic feet of CO 2 per operational hour of all meter/regulator run s operating hour ("EFs,MR,i" for CO 2 calculated using Equation W

- 31 of this subpart). (viii) Meter/regulator run CH4 emission factor based on all surveyed transmission

- distribution transfer stations in the current leak survey cycle, in standard cubic feet of CH 4 per operational hour of all meter/regulator run s operating hour ("EFs,MR,i" for CH4 calculated using Equation W

- 31 of this subpart)." Response: The EPA agrees with the commenter that the termin ology used in § 98.233(q) and § 98.236( q ) should be consistent, and for clarity, we have revised the final rule as suggested by the commenter.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 39
Comment: (§98.238) New definition for Meter/regulator run Meter/regulator run means a series of components used in regulating pressure or metering natural gas flow or both. At least one meter, at least on regulator, or any combination of both on a single run of piping is considered one meter/regulator run. API requests that this definition include a statement that it applies specifically to the onshore natural gas distribution sector, so as not to confuse this definition with “meters/piping” as listed

153in Table W

- 1B for major onshore natural gas production equipment. API suggests the following revision to the definition:

“ Meter run means a series of components used in metering natural gas flow or bot h in the onshore natural gas distribution sector . At least one meter, at least on e regulator, or any combination of both on a single run of piping is considered one meter/regulator run. ” Response: The EPA finds the commenter's suggested revisions to the definition of

“ meter/regulator run ” to be reasonable. We are finalizing changes to clarify that, for the purposes of subpart W, the term “ meter/regulator run ” applies to the natural gas distribution indu stry segment

. The EPA notes that “onshore” is not part of the title for the natural gas distribution industry segment

.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

- HQ

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- 2011

- 051 2

- 0089

- A3 Comment Excerpt Number: 29
Comment: Leaking and venting time

– reporting requirements: Reporting element 98.236(q)(2)(iii) should be reworded to more accurately reflect reality. The component leaking time that is used in Equation W

- 30 is based on broad assumptions; the time is not based on actual field observations. For example, many operators will fix leaks that are detected during the survey, but they may not choose to perform an additional survey to "get credit" for those fixes. It would be i naccurate to characterize this time as "found leaking and operational". Response: The EPA agrees that the provisions of §98.236(q)(2)(iii) may be reworded to clarify that the time leaking is an assumed leak time. We have revised the definition of the term “T p,z ” in Equation W

- 30 and §98.233(q)(2)(iii) to refer to the time the surveyed components were assumed to be leaking and operational.

Commenter Name: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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- 0089

- A3 Comment Excerpt Number: 36
Comment: Leaking and venting time

– reporting requirements: Reporting element 98.236(q)(2)(iii) should be reworded to more accurately reflect reality. The component leaking time that is used in Equa tion W

- 30 is based on broad assumptions; the time is not based on actual field observations. For example, many operators will fix leaks that are detected during the survey, but they may not choose to perform an additional survey to "get credit" for those f ixes. It would be inaccurate to characterize this time as "found leaking and operational". Transmission storage tanks have a similar issue. The following changes are suggested:

15498.236(q)(2)(iii) Average time the surveyed components were found leaking and o perational are assumed to be leaking and operational according to 98.233(q) , in hours (average of ‘‘Tp,z’’ from Equation W

– 30 of this subpart for the component type). Response: The EPA agrees that the provisions of §98.236(q)(2)(iii) may be reworded to c larify that the time leaking is an assumed leak time. We have revised the definition of the term “T p,z ” in Equation W

- 30 and §98.233(q)(2)(iii) to refer to the time the surveyed components were assumed to be leaking and operational

.


### 17.0 Cal c ulation of GHG Emis si o ns from Natural Gas Volume Emissions
17.1 Comments on the use of default or site
- specific gas composition

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Commen t Excerpt Number: 11
Comment: The Use of Site

- Specific Composition Data Should Be Optional, Not Mandatory. Subpart W currently specifies default methane and CO 2 composition values for the onshore natural gas transmission compression; underground natural gas storage; LNG storage; LNG import and export; and local distribution pipeline natural gas industry segments. 17 In the Proposed Rule, EPA has proposed to supple ment this set of default gas composition values for each industry segment with the option to use site

- specific data based on best engineering estimates. 18 In the Proposed Rule, EPA also requests comment on whether the use of site

- specific composition data that EPA proposes to include should be required or optional. 19 Kinder Morgan supports EPA’s proposal to add the option to use site

- specific data as proposed, while retaining the option to use the default methane and CO 2 composition values currently specif ied in Subpart W. Kinder Morgan unambiguously answers EPA’s question about whether the use of site

- specific composition data should be mandatory in the negative. Compressor stations are normally not equipped with gas chromatographs for determination of sit e
- specific gas composition, so the use of default values at those stations without gas chromatographs is absolutely essential. Mandatory reporting of site

- specific gas composition would require the collection of extended gas analyses annually at each compr essor station. That would result in increased costs and burden to natural gas operators with the installation of dozens (or hundreds) of gas chromatographs, ancillary equipment, and additional staff resources to monitor and maintain this equipment. Kinder Morgan and other companies operate gas chromatographs located at strategic points along their pipeline systems, but not at every compressor station or gas plant. The gas chromatographs are primarily used to confirm that the natural gas being transported me ets gas tariff and customer specifications. The default gas composition values currently found in Subpart W should be retained. While the optional use of site

- specific composition data adds flexibility for operators already using site gas

155quality data for other reporting purposes, the use of default composition values simplifies reporting without compromising GHG emission estimates for operators, because natural gas composition values downstream of processing facilities are much less variable than upstream operations. For these reasons, Kinder Morgan strongly supports the Agency’s proposal as written, which provides for optional reporting of site

- specific gas composition data when such data is available.
Footnotes:

17 See 40 C.F.R. § 98.233(u)(2)(iii)

- (vii).

18 Although the Proposed Rule does not propose this option for the underground natural gas storage industry segment, see Proposed Rule at 13445 (not proposing to amend § 98.233(u)(2)(iv)), Kinder Morgan believes this is an oversight by EPA and requests th at the same change be applied to the underground natural gas storage industry segment. See INGAA Comments.

19 Proposed Rule at 1339. Response: The EPA is finalizing revisions to allow facilities the option to use either site

specific composition data or to use a default gas composition for the onshore natural gas transmission compression; underground natural gas storage; LNG storage; LNG import and export; and natural gas distribution industry segments. See Section II.B.13 of the preamble to the final rul e for additional discussion responding to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 46
Comment: Gas Composition: INGAA supports revisions that clarify the optional use of site data or default methane and CO2 values for gas composition for T&S sources. Subpart W currently includes default values for natural gas methane and CO 2 composition for T& S and other segments downstream of processing and also allows the use of site data. EPA added these default values in previous Subpart W amendments in response to INGAA comments. INGAA has also requested that the rule clearly allow operators to use specifi c data rather than the default values, with this choice optional at the discretion of the operator. For example, some operators are using site

- specific gas quality data for other reporting purposes and prefer consistency. The optional use of site data or d efault values provides flexibility, while the use of default values simplifies reporting without compromising estimates, because gas quality downstream of processing is much less variable than upstream operations. Thus, INGAA supports the Proposed Rule rev ision to §98.233(u)(2)(iii) that clearly allows default values or site data based on best available data, "either a default 95 percent methane and 1 percent carbon

156dioxide fraction for GHG mole fraction in natural gas or site specific engineering estimates based on best available data." In addition, at 79 FR 13398 EPA requests comment on whether the use of site data should be required or optional . INGAA strongly supports maintaining the option to use default values or site

- specific data at the discretion of the reporter. As noted above, default values were added in previous amendments and EPA should not undermine earlier progress in this rulemaking. If additional background is desired, EPA should refer to earlier comments and decisions regarding the use of d efault composition for T&S. Response: The EPA is finalizing revisions to allow facilities the option to use either site

- specific composition data or to use a default gas composition for the onshore natural gas transmission compression; underground natural gas storage; LNG storage; LNG import and export; and natural gas distribution industry segments. See Section II.B.13 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

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- A1 Comment Excerpt Number: 7
Comment: Mandatory Use of Site Specific Gas Composition. The proposed rule adds the option of using site

- specific gas composi tion rather than the current default gas composition and the preamble requests comment on whether using site specific data should be mandatory. The mandatory use of site specific gas composition is potentially problematic due to the additional sampling and recordkeeping required. Unless there is a significant difference between the site specific composition and the default composition, the additional cost would not likely be warranted. We do not maintain site

- specific gas compositions at each station and th e logistics and cost of conducting additional gas analysis will increase the program costs. We request that the agency does not make the use of site

- specific gas composition mandatory because the default value of 95% methane and 1 % carbon dioxide is conse rvative in that most natural gas compositions that are significantly different than the default would have a lower CO 2 e than that of the default composition. The use of site

- specific gas composition should be used only if it is available. We ask that the a gency allow reporters to have the option of sampling should they choose to do so. Response: The EPA is finalizing revisions to allow facilities the option to use either site

specific composition data or to use a default gas composition for the onshore nat ural gas transmission compression; underground natural gas storage; LNG storage; LNG import and export; and natural gas distribution industry segments. See Section II.B.13 of the preamble to the final rule for additional discussion responding to this comme nt.

157Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 53
Comment: The Proposed Rule inadvertently omits analogous revi sions for underground storage. EPA completed the revision noted above to §98.233(u)(2)(iii) and (v)

– (vii), which encompasses all segments downstream of processing other than section (iv) for underground storage. INGAA had requested this revision for T&S

– i.e., natural gas transmission compression and underground natural gas storage segments. The preamble indicates that EPA intended to include this revision for underground storage and this appears to be an oversight. If not, EPA has not explained why this option is not allowed for underground storage. The preamble text regarding underground storage follows: "We are proposing to allow either the use of site

- specific composition data for natural gas transmission compression and underground natural gas storag e facilities or the use of a default gas composition..." [79 FR 13398] For consistency with (u)(2)(iii) and the preamble discussion, §98.233(u)(2)(iv) for underground storage should be revised consistent with the proposed text in §98.233(u)(2)(iii). It is ap propriate to clearly provide the same flexibility to underground storage as is provided for transmission compression and other downstream segments. Response: The commenter is correct that it was the EPA's intention to revise § 98.233(u)(2)(iv); however, th is change was inadvertently omitted from the proposed rule text. In this final rule, we have revised § 98.233(u)(2)(iv) to be consistent with the changes to § 98.233(u)(2)(i) through (iii) and (v) through (vii) to allow for the use of either site

- specific or default gas compositions for all industry segments. See Section II.B.13 of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of Amer ica (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 48
Comment: Gas Composition: EPA requested comment on whether T&S sources should be required to use site data on gas composition or its use should be optional. The Proposed Rule clarifies that default gas composition or site

- specific data can be used. INGAA requested and supports the option to use site data or default values at the operator’s discretion. In addition, EPA should address an apparent oversight, and inc lude the same text regarding optional use of site data in §98.233(u)(2)(iv) for the underground storage segment. Response: The commenter is correct that it was the EPA's intention to revise § 98.233(u)(2)(iv); however, this change was inadvertently omitted from the proposed rule text. In this final rule, we have revised § 98.233(u)(2)(iv) to be consistent with the changes to § 98.233(u)(2)(i) through (iii)

158and (v) through (vii) to allow for the use of either site

- specific or default gas compositions for all i ndustry segments. See Section II.B.13 of the preamble to the final rule for additional discussion responding to this comment.



### 17.2 Comments on the need to use “actual” versus “standard” conditions

Commenter Name: Carrie B. Crumpton Commenter Affiliation: CONSOL Energy, Inc. Document Control Number: EPA

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- A1 Comment Excerpt Number: 6 , 8 and 9
Comment: Requiring the conversion of gas flow rates from "standard conditions" to "actual conditions" when applying required estimation methodol ogy is burdensome and overly complicated. These estimations then have to be converted back into standard conditions for reporting under the regulatory requirements. Since instrumentation used in the industry typically measures gas flow rates in standard co nditions, CONSOL request the EPA to revise Equations W

- 3, W

- 4A, W

- 4B, W

- 7, W

- 17A, W

- 17B, W

- 34, W

- 39A, and W

- 39B to reflect that the measured gas volumes and/or estimated gas volumes used in these equations, and the resulting emissions, are in standard cond itions to better meet reporting requirements and consistency. Response: The EPA recognizes that there are flow or volume measurement systems that automatically convert measurements to standard conditions. It was not our intent to require facilities to con vert this data to actual conditions to fulfill the certain calculation and reporting requirements, then convert the volumes back to standard conditions prior to determining GHG mass emissions. We are finalizing revisions to the introductory text at § 98.233 and § 98.236 to clarify that use of systems that automatically correct to standard conditions is allowed for these equations. See Section II.B.13 of the preamble to the final rule for additional discussion responding to this comment

.

Commenter Name: Kar in Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 17 , 19 and 20
Comment: Gas Flow Rate Measurements. In discussions with EPA, API has emphasized the need to use industry standard conditions for gas flow and volume measurements. API urges EPA to revise the terms for Equations W

- 3, W

- 4A, W

- 4B, W

- 7, W

- 17A, W

- 17B, W

- 39A, and W

- 39B to reflect that measured or estimated gas volumes used in these equations and the r esulting emissions are in standard conditions. This is particularly the case for Equation W

- 34 because it makes no sense to take a gas flow rate already determined in standard conditions to convert it to actual conditions just to apply a required estimatio n methodology which, in turn, will again convert it back to standard conditions per the rule requirements.

159Response: The EPA recognizes that there are flow or volume measurement systems that automatically convert measurements to standard conditions. It wa s not our intent to require facilities to convert this data to actual conditions to fulfill the certain calculation and reporting requirements, then convert the volumes back to standard conditions prior to determining GHG mass emissions. We are finalizing revisions to the introductory text at § 98.233 and § 98.236 to clarify that use of systems that automatically correct to standard conditions is allowed for these equations. See Section II.B.13 of the preamble to the final rule for additional discussion respo nding to this comment

.

Commenter Name: V. Bruce Thompson Commenter Affiliation: American Exploration & Production Council (AXPC) Document Control Number: EPA

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- A2 Comment Excerpt Number: 10
Comment: AXPC and the Alliance request that EPA allow for the use of site

‐ specific sampling analyses for use in modeling acid gas removal systems, dehydration units, and storage tanks. These analyses are sometimes permit required or available for other reasons and we believe that their use sho uld be allowed in lieu of a sub

‐ basin analysis where they are available as they are more representative. However, AXPC believes that the option to use the sub

‐ basin analysis needs to be retained for those sources that do not have site

‐ specific analyses ava ilable. Likewise, we support the optional use of site

‐ specific samples for calculating pneumatic device emissions. Response: The commenter refers to calculation methods in § 98.233(d)(4), (e)(1), and (j)(1) that require modeling using standard simulation s oftware packages, such as AspenTech HYSYS®, API 4679 AMINECALC, GRI

- GLYCalcTM, or API 4697 E&P Tank. The rule currently provides for the use of either site

- specific analyses or sub

- basin analyses for use with these methods. For example, for acid gas removal units, § 98.233(d)(4) provides for parameters determined by engineering estimate and process knowledge based on best available data. For dehydrators, § 98.233(e)(1)(xi) provides for use of wet natural gas composition as calculated in § 93.233(u)(2)(i) and (u )(2)(ii), which allows for the use of either a sub

- basin or facility analysis, or other representative analysis, standard method, or standard industry practice. For onshore production storage tanks, § 98.233(j)(1) specifies that all parameters must be deter mined by engineering estimate and process knowledge based on best available data and provides that facilities perform an analysis of oil composition on a sub

- basin basis only if a current analysis is not available. Since reporters currently have the abilit y to use site

- specific analyses for these calculation methods, we are making no revisions to the final rule.

160

### 18.0 Onshore Petroleum and Natural Gas Production and Natural Gas Distribution Combustion Sources

Commenter Name: Karin Ritter Commenter Affiliation : American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 74
Comment: Onshore petroleum and natural gas production and natural gas distribution combustion emissions. Revisions to §98.233(z): EPA is proposing clarifying text revisions. These include specifying that the term Va in Equations W

- 39A and W

- 39B is the actual volume, the Y terms refer to mole fractions instead of “concentrations”, and N2O mass emissions are calculated in tonnes of N2O ins tead of tonnes of CO2e. Industry practice is to calculate or meter gas volume in standard conditions, not actual conditions. API requests that Equations W

- 39A and W

- 39B be revised to reflect that the gas volume terms and the resulting emissions are in stan dard conditions. Response: See response to comment EPA

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- A1, Excerpt 6 in Section 17.2 of this document.
Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 75
Comment: API requests the option to use a site specific heating value in Equation W

- 40 for field gas or process vent gas, where this information is available. This is similar to EPA’s consideration of the use of site specific gas composition data for §98.233(a) and (b). Response: The EPA agrees with the commenter. We had proposed to revise the definition of the “HHV” term in Equation W

- 40 specifically to indicate that the higher heating value must b e determined on fuel

- specific basis although we provided a default HHV value when the fuel is field or process vent gas. However, we did not intend to mandate the use of this default HHV value when site

- specific data are available to determine HH V for thes e fuels. To further clarify our intent , we are revising parameter “ HHV ” of Equation W

- 40 as follows: “ Higher heating value of fuel, mmBtu/unit of fuel (in units consistent with the fuel quantity combusted). For the higher heating value for field gas or pro cess vent gas, you may use 1.235 × 10 − 3 mmBtu/scf for HHV. For natural gas that in not of pipeline quality or that has a high heating value of less than 950 Btu per standard cubic foot, use a site

- specific higher heating value (based on best available data ).”

161

### 19.0 Revisions to Missing Data Provisions
19.1 Revisions to § 98.235 to specify the use, treatment, and reporting of missing data

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Comment Excerpt Number: 15
Comment: Acid Gas Removal Vents Section 98.235(a) states that where there is a missing sample from quarterly gas samples taken pursuant to § 98.233(d)(8)(ii), concerning emissions calculations for acid gas remov al vents, "you must substitute the average value of the last four samples for which data are available." The text of § 98.235(a) should be amended to accommodate new acid gas removal vents that may not have four previously taken samples available (e.g., fo r a new unit that starts up during the reporting year or at facilities that were previously below the reporting threshold). For this reason, Kinder Morgan proposes that § 98.235(a) be modified as indicated in Figure 2. Figure 2: Propos ed Modifications to 40 C.F.R. § 98.235(a). Proposed 40 C.F.R. § 98.235. Procedures for estimating missing data.

. . . (a) If you choose to take quarterly gas samples as allowed in § 98.233(d) in lieu of using a continuous gas analyzer, and there is a missing sample, you must substitute the average value of the last four samples for which data are available. Where the last four samples are not available, you should use the average of all available samples that are representative. Response: The EPA agrees with the commenter that there may be situations , particularly for new acid gas removal vents, when the reporter will not have results available from four previous quarterly samples. In considering potential clarifications for the missing data procedures for acid gas removal vents in light of the various scenarios of data availability, the missing data procedures for this so urce mirrored the procedures proposed in § 98.235(d)

. Furthermore, we determined that the use of the average of a “before” and “after” sample would provide as good an estimate of the missing data as the average of four “before” samples. Therefore, we are ge neralizing the proposed missing data procedures in § 98.235(d) to apply to all measurements that are required to be performed quarterly or more frequently. See Section II.C of the preamble for further discussion regarding missing data procedures for acid ga s removal vents

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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162Comment: In the proposed rule, the BAMM section, §98.234(f) is d eleted and the missing data section §98.235 is significantly revised. As EPA well knows, use of BAMM to address issues with requirements under the rule was common for the 2011, 2012, and 2013 reporting years. API assumes that EPA is proposing to revise §98 .235 to provide an avenue to compliance for instances where the complex and voluminous requirements for data collection and measurement are not fully met. However, API and its members find the missing data procedures in the proposed rule to be somewhat con fusing, unnecessarily burdensome, and not sufficient to provide the flexibility needed to enable compliance. Specifically, API provides the following commentary regarding the proposed missing data procedures and suggested changes to address the problems id entified. The proposed language at §98.235(d) poses a problem where “before” or “after” values are not available for a data element that requires measurement. The proposed language is: (d) For each missing value of a parameter that should have been measure d using a continuous flow meter, composition analyzer, thermocouple, or pressure gauge, you must substitute the arithmetic average of the quality

- assured values of that parameter immediately preceding and immediately following the missing data incident. If the “after” value is not obtained by the end of the reporting year, you may use the “before” value for the missing data substitution. If, for a particular parameter, no quality

- assured data are available prior to the missing data incident, you must use th e first quality assured value obtained after the missing data period as the substitute data value. A value is quality

- assured according to the procedures specified in §98.234.
Instances where a “before” or “after” value is not available for substitution ca n occur and will require additional flexibility to enable compliance. For example:

• Where information from a third

- party equipment operator, such as a third

- party operated dehydrator greater than 0.4 MMSCF/Day, is not received, the reporter may very well no t have either “before” or “after” data to substitute in order to run the prescribed model to calculate emissions. Although, in general, the calculation procedures at §98.233(e)(1) specify that an engineering estimate based on best available data may be use d in this instance, the reporter has limited or no data on which to base an engineering estimate. Unless the reporter is successful in getting the required data they will have no ability to substitute values in order to comply. This situation is exacerbate d by the significantly expanded requirements for reporting of data elements in §98.236(e).

• Where taking a required measurement on a compressor vent source is not safe due to facility configuration or other characteristics, and use of an acoustic device is not feasible due to background vibration noise, the reporter will not have “before” or “after” data available for substitution. API recognizes and appreciates that EPA has eliminated many of these potential issues by enabling measurement of manifolded comp ressor vents and changing compressor vents routed to flare to be included in the flare calculations, these changes will not eliminate the potential for such unsafe instances to occur.

• Where a well completion in a sub

- basin category/county/well

- type combina tion is a single unique well for a particular reporter and the measurement equipment necessary to measure flowback or calculate flowback malfunctions, a reporter will not have “before” data to substitute. Where the reporter does not drill and complete anot her well in the same sub

- basin

163category/county/well

- type combination prior to the reporting due date (or ever) they will have no “after” data to substitute. This scenario becomes more likely with EPA’s proposed expansion of “well types”, addressed elsewher e in these comments, that will in theory, quadruple the number of completions and/or workovers that require either measurement or calculation of flowback volume post hydraulic fracturing of a well. In prior years a reporter would rely on BAMM and use data from an analogous source to “fill in” the data which was not obtained. However, with the elimination of BAMM this option is no longer available. To solve this issue API recommends modifying 98.235 (d) as follows: (d) For each missing value of a parameter t hat should have been measured using a continuous flow meter, composition analyzer , thermocouple , or pressure gauge, you must substitute the arithmetic average of the quality

- assured values of that parameter immediately preceding and immediately following the missing data incident. If the “after” value is not obtained by the end of the reporting year, you may use the “before” value for the missing data substitution. If, for a particular parameter, no quality

- assured data are available prior to the missing d ata incident, you must use the first quality

- assured value obtained after the missing data period as the substitute data value. A value is quality

- assured according to the procedures specified in §98.234. Where a “before” or “after” value for a data elemen t is not available a reporter may substitute a value based on engineering estimate using the best available data. Modifying §98.235(d) to address those instances where “before” or “after” values are not available for data substitution is necessary if BAMM is to be eliminated as EPA has proposed. If EPA is not willing to make these changes, API is more opposed to BAMM elimination that discussed elsewhere in these comments. Response: The proposed provisions of § 98.235(d) were not meant to address measurement data that are required annually or biannually or situations such as the supply of information by third

party vendors. Reporters should know what information is needed for the annual reports and must make every effort to collect all necessary data . If repo rters elect to use third

- party vendors for certain services, the information needed for the annual reports may be specified in the third

party contract or agreement to ensure the necessary information is provided. We are not including any missing data prov ision in the final rule to allow for use of third

- party operators that do not provide the required information needed for determining the emissions from dehydrators or other emissions sources . We are providing missing data provisions specific to annual mea surement requirements. See Section II.C of the preamble to the final rule for further discussion regarding the final missing data procedures

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Numbe r: EPA

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- A2 Comment Excerpt Number: 78
Comment: In the revisions to §98.235(d) above, API requests that “thermocouple” be removed from the list of measurement devices applicable to the missing data procedures. The Monitoring

164and QA/Q C requirements under §98.234(b) do not list thermocouples as a measurement device. So, best engineering estimates are already permitted for missing thermocouple data. Response: The EPA has determined that the error is in the omission of temperature monito rs (thermocouples) in the list of monitors §98.234(b). Many of the calculation procedures require the determination of temperature. The provisions of §98.235(d) are intended to provide guidance for reporters to determine a substitute data value for situations in which a continuous or frequent measurement data are missed , and we have determined that these procedures should be applied when temperature measurement data needed for the calculations are missed

. We are not amending §98.234(b) at this time because no revisions to this paragraph were proposed. However, we will consider whether it is necessary to make revision to §98.234(b) in future regulatory actions

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Commenter Name: Darrell R. Johnson Commenter Affiliation: Sout hern California Gas Company (SoCal Gas) Document Control Number: EPA

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- A2 Comment Excerpt Number: 3
Comment: §98.235(e) should be revised to allow best engineering estimates for the first reporting year for facilities that become new ly subject to Subpart W. An unexpected late year (e.g., December) event (e.g., a large pipeline blow down or increased compressor throughput at a transmission station due to increased customer demand for natural gas in the winter months) could trigger firs t time applicability for a facility. An allowance to use best engineering estimates for six months would not cover the entire calendar year, and under this circumstance the facility would require the use of best engineering estimates for the initial report ing year because the previously not subject facility would not have been collecting all data required for Subpart W reporting. The ongoing reporting obligation would require measurements, data collection, etc. in the second year, shortly after the facility applicability change following a late year triggering event. To address late year events that trigger first time facility applicability, SoCal Gas recommends that the following revisions be made to §98.235(e):

" For the first six months of required data co llection, For the first reporting year, facilities that become newly subject to this subpart W may use best engineering estimates for any data that cannot reasonably be measured or obtained according to the requirements of this subpart. Response: The EPA contends that 6 months is enough time for a newly subject facility to begin using the methods required in § 98.233. This time period is consistent with requirements in the final subpart W rule, in which we previously allowed the use of BAMM for the first si x months of data collection to allow reporters newly subject to subpart W to comply. See Section II.C of the preamble to the final rule for additional discussion respon ding to this comment.

165Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 13
Comment: §98.235(g) and related reporting requirements in §98.236(bb) should be revised to clarify broad applicability.
As discus sed above, it is imperative that missing data provisions address situations where measurement cannot be conducted or alternatives are necessary. Since §98.235(g) addresses "other" situations not specifically defined within other missing data subsections, i t appears that §98.235(g) is intended to have broader applicability than the provisions in §98.235(a)

– (f). However, INGAA recommends that EPA include clarifications in order to clearly address measurement and monitoring related issues. Additional explana tion of §98.235 terminology (e.g., "activity data") is also needed. This can be accomplished via additional discussion and explanation in the preamble or related background memos (e.g., the technical support memo), but INGAA’s preferred approach for clarif ying applicability to measurement data is to also include minor clarifying revisions to §98.235(g): "(g) For each missing value of any activity data or measurement not described in this section you must substitute data value(s) using the best available est imate(s) of the parameter(s), based on all available process data (including, but not limited to, processing rates, operating hours) or other measurements ." INGAA also recommends complementary discussion in the preamble of the final rule. In addition, the associated reporting obligation should be revised for consistency and clarity. INGAA recommends the following revisions to §98.236(bb):
"... (3) The description of the unique or unusual circumstance or measurement barriers that led to missing data use, inclu ding information on any equipment or components involved and any procedures that were not followed. (4) The description of the procedures used to substitute an unavailable value of a parameter. (5) The description of how the owner or operator will avoid or minimize the use of missing data in the future, such as mitigation strategies or changes to standard operating procedures." As discussed in comments above, Subpart W measurement requirements are inextricably linked to access to alternative measurement and estimation methods when measurement is precluded. These revisions are requested to provide clarity, and additional discussion in the preamble or support documents should further elucidate EPA’s intent. Without this interpretation and clear applicability o f missing data provisions, INGAA strongly objects to the elimination of BAMM provisions. Response: The provisions proposed in §98.235(g) were intended to be used for data for which direct measurement s are not required, such as the time a compressor was in a specific mode of

166operation. The provisions in this paragraph were not intended to be applied to data required to be directly measured so we are not making the revision suggested by the commenter to §98.235(g)

. With respect to the reporting requirements, these reporting elements cited by the commenter have been significantly revised and the edits suggested by the commenter are not applicable to the final missing data reporting requirements. See Section II.C of the preamble to the final rule for further di scussion regarding the missing data procedures and the reporting requirements for the use of missing data procedures in the final rule

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Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

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Comment: The solution proposed by the rule to address situations when data is not available is found in the "missing data" provisions (40 C.F.R. 98.235, as proposed) which read: " ... whenever a val ue of a parameter (emphasis added) is unavailable for a GHG emission calculations required by this subpart (including, but not limited to, if a measuring device malfunctions during unit operations, a required gas sample is not taken, or activity data are n ot collected), you must follow the procedures specified in paragraphs (a) through (h)." It is not clear if this means that a reporter would be allowed to estimate calculation inputs only, or if it means that they can also estimate emissions from points tha t are required to be directly measured. If it means that emissions can be estimated for sources that are required to be directly measured, then this is a viable solution; if not, then this will not solve the problem of inaccessible monitoring points that m ay be new to the program as described above. We ask that EPA review this provision and clearly indicate the circumstances, if any, where estimations per the "missing data" provisions would not be allowed. Further, we ask that the agency consider minor clar ifying revisions to §98.235(g): "(g) For each missing value of any activity data or measurement not described in this section you must substitute data value(s) using the best available estimate(s) of the parameter(s), based on all available process data (i ncluding, but not limited to, processing rates, operating hours) or other measurements." Response: The provisions in §98.235 are applicable to parameters used for the GHG emission calculations (i.e., used in the equations in §98.233). S ome of these “param eters” are direct emission measurements (e.g., for compressors) that are then used in subsequent reporter

- specific emission factor calculations. We have clarified specific missing data procedures in §98.235 based on the measurement frequency required for t hat parameter. The provisions proposed in §98.235(g) were intended to be used for data for which direct measurements are not required, such as the time a compressor was in a specific mode of operation. The provisions in paragraph §98.235(g) were not intend ed to be applied to data required to be directly measured so we are not making the revision suggested by the commenter to §98.235(g). See Section II.C of the preamble to the final rule for further discussion regarding the missing data procedures and the re porting requirements for the use of missing data procedures in the final rule

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167Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Comment Excerpt Number: 6
Co mment: Clarification of "Activity Data" for Emissions Calculations Section 98.235(g) states that for each missing value of "activity data" not described in § 98.235, the reporting entity must substitute data values using the best available estimates of pa rameters, based on all available process data. Kinder Morgan believes the Agency intends for this term to be interpreted broadly and supports such an approach. 7 Consistent with this understanding, Kinder Morgan urges EPA to clarify that the term "activity data" encompasses the following:

• D ehydrator vents: the following data elements used in Equation W

- 6 (part of Calculation Method 3) in § 98.233(e): atmospheric pressure (P1); pressure of the gas being discharged (P2); percent of packed vessel volume that is gas (%G); and the number of dehydrator openings in the calendar year (N).

• B lowdown vent stacks: the following data elements used in Equations W

- 14A and W

- 14B in § 98.233(i): number of occurrences of blowdowns for each unique physical volume in the calenda r year (N); temperature at actual conditions (Ta,Ta,p); absolute pressure at actual conditions (Pa, Pa,b,p, Pa,e,p); and compressibility factor at actual conditions (Za).

• Equipment leaks by population count: the following data elements used in Equation W

- 3 2A in § 98.233(r): total number of underground natural gas storage wellhead components (Counte); and average estimated time that each emission source type associated with the equipment leak emission was operational in the calendar year, in hours (Te).

• GHG volumetric emissions using actual conditions: the following data elements used in Equation W

- 34 in § 98.233(t): temperature at actual conditions (Ta); absolute pressure at actual conditions (Pa); compressibility factor at actual conditions for GHGi (Za). Accordingly, Kinder Morgan requests that EPA make the clarifications noted above by modifying proposed § 98.235(g) as indicated in Figure 1: Proposed 40 C.F.R. § 98.235. Procedures for estimating missing data.

. . . (g) For each missing value of any activi ty data (including any information or data necessary to comply with this subpart) not described in this section, you must substitute data value(s) using the best available estimate(s) of the parameter(s), based on all available process data (including, but not limited to, processing rates, operating hours).
FOOTNOTE:

7 See Proposed Rule at 13404 (noting that the new missing data procedures would apply to many new areas of Subpart W, and connecting that to the proposed removal of BAMM).

168Response: The a ctivi ty data referred to in § 98.235(g) includes data describing facility activities, such as counts . For example, activity data would include the number of dehydrator openings in the calendar year, number of occurrences of blowdowns for each unique physical vol ume in the calendar year, and total number of underground natural gas storage wellhead components. The provisions of § 98.233(g) do not refer to values that are already determined using engineering estimates based on best available data or that are required to be measured , such as pressures or temperatures

. The EPA has provided specific missing data procedures to address missing measured values in other paragraphs of § 98.23 5

. We are not incorporating the language suggested by the commenter because it is too broad. See Section II.C of the preamble to the final rule for further discussion regarding the missing data procedures and the reporting requirements for the use of missing data procedures in the final rule.

Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Company (SoCal Gas) Document Control Number: EPA

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- A2 Comment Excerpt Number: 5
Comment: §98.235(g) and related reporting requirements in §98.236(bb) should be revised to clarify applicability of the Missing Data provisions. As discussed above, it is imperative that missing data provisions cover circumstances where standard measurement procedures cannot be utilized, making alternative methods necessary. Because §98.235(g) addresses "other" situati ons ( I. e., not specifically defined within other missing data subsections), it appears that §98.235(g) is intended to have broader applicability than the other subsections. SoCal Gas recommends minor revisions to §98.235(g) to more clearly address measurem ent and monitoring related issues: "For each missing value of any activity data or measurement not described in this section you must substitute data value(s) using the best available estimate(s) of the parameter(s), based on all available process data (in cluding, but not limited to, processing rates, operating hours) , other measurements or information. " In addition, the associated reporting obligation should be revised for consistency and clarity, and the following revisions to §98.236(bb) are recommended:
"... (3) The description of the unique or unusual circumstance or measurement barriers that led to missing data use, including information on any equipment or components involved and any procedures that were not followed. (4) The description of the proced ures used to substitute an unavailable value of a parameter. (5) The description of how the owner or operator will avoid or minimize the use of missing data in the future, such as mitigation strategies or changes to standard operating procedures." Response : See response to comment EPA

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169Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 80
Comment: The proposed language at §98.235(g) is not clear and needs to be revised for clarity. The requirement to use “all available process data (including but not limited to, processing rates, operating hours).” when making a “best available estimate ” is overly broad and not clear. For instance, a reporter may be making an estimate that is related to or dependent on a small subset of process data, in which instance the requirement to use “all available process data” is not useful or logical. To addres s this issue API recommends modifying the proposed §98.235(g) language as follows: Existing proposal language: (g) For each missing value of any activity data not described in this section, you must substitute data value(s) using the best available estimat e(s) of the parameter(s), based on all available process data (including, but not limited to, processing rates, operating hours). Suggested language: (g) For each missing value of any activity data not described in this section, you must substitute data va lue(s) using the best available estimate(s) of the parameter(s), based on all applicable and available process or other data (including, but not limited to , e.g. processing rates, operating hours). Response: The EPA agrees with the commenter that the lang uage in § 98.235(g) could be made clearer by replacing the term “all available process data” with the term “all applicable and available process data” . We have not made the changes associated with the parenthetical phrase to keep the language consistent wit h similar language throughout the rule. The final language for § 98.235(g) is as follows: “Unless addressed in another paragraph of this section , for each missing value of any activity data, you must substitute data value(s) using the best available estimate(s) of the parameter(s), based on all applicable and available process or other data (including, but not limited to, processing rates, operating hours).”

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P D ocument Control Number: EPA

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- A1 Comment Excerpt Number: 17
Comment: Specific Missing Data Provision for Centrifugal Compressors, Reciprocating Compressors, and Equipment Leak Surveys : Because Subpart W requires detailed annual meas urements of emissions of centrifugal compressors and reciprocating compressors, and to avoid any confusion with or misinterpretation of the other missing data provisions under § 98.235, Kinder Morgan recommends the addition of

170separate missing data provisi ons specific to each of these compressor types, as indicated in subparagraphs (i) and (j) of Figure 4. Because Subpart W requires annual leak detection surveys for subject facilities, but reporters may not know whether subject facilities need surveys until after the reporting year has concluded, Kinder Morgan recommends the addition of a separate missing data provision specific to leak detection surveys as indicated in subparagraph (k) of Figure 4. Figure 4: Proposed Additions to 40 C.F.R. § 98.235.

. . . ( i) For any leak measurements for centrifugal compressors (including continuous measurements) under Section 98.233(o) that were unable to be completed during a reporting year, the use of best available data considered representative of the compressor(s) may be substituted and this representative data may include, but is not limited to, the use of the reporter emission factor for the corresponding compressor

- mode source combination for the reporting year. The reporter emission factor(s) are calculated using E quation W

- 23 under Section 98.233(o)(6)(iii). (j) For any leak measurements for reciprocating compressors (including continuous measurements) under Section 98.233(p) that were unable to be completed during a reporting year, the use of best available data considered representative of the compressor(s) can be substituted and this representative data may include, but is not limited to, the use of the reporter emission factor for the corresponding compressor

- mode source combination for the reporting year. The reporter emission factor(s) are calculated using Equation W

- 28 under Section 98.233(p)(6)(iii). (k) If a facility is unable to complete its leak detection survey during the reporting year in which the leak detection survey was required to be performed, tha t facility shall document the reason(s) for not completing the leak survey during the reporting year and the leak detection survey will be completed as soon as possible in the subsequent calendar year, but no later than 90 days after the beginning of the s ubsequent calendar year. This leak detection survey may only be used for the reporting year’s emission estimation and it may not be used for the subsequent calendar year’s emission estimation. The facility shall perform another leak detection survey perfor med for the subsequent calendar year, and a minimum of 30 days must separate the two leak detection surveys. Response: The EPA has added specific missing data procedures for measurements that are required to be performed annually; these procedures require repeat measurement as soon as possible, including in the subsequent calendar year, similar to the language suggested by the commenter for paragraph (k). These missing data procedures are applicable to all measurements that required to be performed annuall y; we are not providing different, source

- specific missing data procedures as suggested by the commenter

. For compressors that use continuous measurements, the appropriate missing data procedures are outlined in the proposed paragraph at §98.235(d); these provisions are finalized, with minor revisions as paragraph §98.235(b)

. With respect to new sources, we proposed specific provision s for them at §98.235( e ) and (f) ; these provisions are finalized with minor clarifying revisions (to broaden the applicabilit y of paragraph (f) to “sources” rather than “wells”).

171Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 11
Comment: Eliminating BAMM compromises the ability to comply unless Missing Data provisions address alternative approaches. The Proposed Rule deletes the BAMM section, §98.234(f), and significantly revises §98.235, which addresses Missing Data. Since access to alte rnatives is a regulatory imperative, especially when measurement is required, INGAA presumes that proposed Missing Data revisions are intended to address all types of BAMM requests previously approved by EPA. Several new provisions are proposed for the mis sing data section. Section 98.235(b) contemplates a measurement issue associated with transmission tanks; §98.235(d) contemplates certain aspects of missing data associated with a measurement, §98.235(e) and (f) consider facility and source

- level issues, a nd §98.235(g) broadly covers situations other than those addressed in those defined in §98.235(a)

– (f). If the BAMM section is deleted, it is imperative that §98.235 address all scenarios that have been addressed for 2011 through 2014 compliance using BAM M requests. Comment 6 recommends revisions to clarify and improve proposed revisions to §98.235 based on example scenarios where missing data provisions would need to be applied. In some cases, it is apparent that missing data provisions would apply. For e xample:

• BAMM has been requested to address the occurrence of (or potential for) a late year event (e.g., unexpected blowdown) that results in a facility that has not reported becoming newly subject. §98.235(e) addresses the scenario by allowing best engine ering estimates.

− However, INGAA recommends the rule allow the use of best estimates for the first reporting year. As an example, facility emissions could be well below the reporting threshold for many years, until a single late year (e.g., December) pipe line blowdown within the station boundary triggers applicability. A six month allowance for using best engineering estimates does not provide enough coverage, and in this scenario, the facility should be allowed to use best engineering estimates for the in itial reporting year. The ongoing reporting obligation would require measurements, data collection, etc., in the second year, shortly after applicability changes following a late year triggering event. INGAA recommends the following revision to §98.235(e):

" For the first reporting year , facilities that become newly subject to subpart W may use best engineering estimates for any data that cannot reasonably be measured or obtained according to the requirements of this subpart."

• §98.235(b) addresses the situat ion where transmission tank monitoring is not completed, and indicates that leakage for the entire year should be assumed.

172− However, the provision does not indicate what leak rate should be assumed. Previous data could be used if available. If previous da ta is not available, a leak rate equivalent to the leak threshold defined in §98.234(a)(5) could be used. The reporting obligation in §98.236(bb)(5) would identify how this missed data scenario would be avoided in the future. There may be scenarios where s afe access is precluded. For a number of examples where BAMM was previously requested, similar scenarios will occur in 2015 and beyond. Missing data provisions should apply to these situations. Revisions are needed to add or clarify applicability of the mi ssing data provisions and EPA’s intent must be clearly understood to avoid implementation or compliance problems. Primary concerns include:

• Late year changes at a facility that trigger reporting for the first time or where a new source is added at a subjec t facility. Data many not be available and best engineering estimates should be allowed.

• Applicability is clear for the former case (newly affected facility) but not the latter (subject facility with new emissions source);

• Vent lines that cannot be safely or feasibly measured and where acoustic device measurement is not an option;

• Data that is not available for compressor measurements mandated in a specific mode, especially when a wealth of measurement data is available to develop operator emission factors for modes not measured. Several more specific examples and related discussion follows:

• §98.235(f) applies for subject production facilities when new wells are added. INGAA supports this provision, but its applicability should be broadened to cover similar scenarios for all Subpart W segments

– i.e., the scenario where there is a change (e.g., new source) at a subject facility, and the reporter cannot reasonably acquire necessary data.

− For example, BAMM has been requested to address unforeseen changes, esp ecially late in the year, at an affected facility because it may not be feasible or reasonable to collect all required data for a newly affected source at an existing, reporting facility. For example, at an existing compressor station, new compression capa city may be added to address anticipated demand. The compressor may come on

- line late in the year (e.g., December) in preparation for the heating season. In this case, the new source (compressor) should be provided the same allowance afforded to wells in § 98.235(f). Comment 6 provides recommended revisions to §98.235(f).

• INGAA has consistently requested reasonable approaches for vent lines that cannot safely be measured or are inaccessible (e.g., cannot add a port at a lower elevation). EPA has provided the acoustic device method to address some cases, but there are still instances where measurement is not possible. For example:

− Vent line access is not safe or feasible to access and acoustic device measurement of the relevant valve is not possible. Some valves are buried and not accessible unless exhumed;

173other valves may include insulation or have other accessibility problems that eliminate the acoustic method as an option.

− Vent line is not safe or feasible to access (e.g., wet seal degassing vent) and valve leakage measurement (i.e., acoustic method) is not applicable.

• For "missing" vent measurements, §98.235(d) contemplates missing data associated with a measured parameter. However, it does not appear to address the situation where an annual measureme nt is not completed, such as a vent line where measurement is not feasible. This implies that §98.235(g) would need to apply for missing vent measurements.

− It is not clear if §98.235(g) is intended to include missing compressor vent measurements. Comment 6 recommends revisions to §98.235(g) to clarify applicability. Alternatively and as discussed above, a provision similar to §98.235(b) could be added to address compressor vents in a similar manner as tank vents.

− Missing data provisions must apply for s cenarios when vent measurement is not feasible. If not, INGAA strongly opposes eliminating BAMM. Clarity is needed and can be provided through revision to one or more subsections in §98.235.
In addition to or as an alternative to the revisions recommended below for section §98.235(g), missed compressor vent and rod packing measurements could be added to the tank monitoring provisions in §98.235(b). Or, a similar, separate provision could be added for compressor measurements. In this case, the operator shoul d use reporter emission factors to estimate emissions for all operating modes for the vent not measured. Response: The EPA indicated in the preamble to the proposed rule that missing data procedures may provide clarity for reporters who may have unintentionally missed collecting required data, but the missing data procedures are not intended to replace BAMM. By the 2015 re porting year, facilities will have had four years to implement any necessary changes in equipment in order to fully comply with subpart W, which we have determined to be sufficient time to make any equipment modifications or installations. Furthermore, m an y of the revisions that we are finalizing were specifically proposed to address the com menter ’s concerns related to BAMM:

• For a late year event (e.g., unexpected blowdown) that results in a facility that has not reported becoming newly subject, we are fina lizing the missing data provisions in proposed §98.235(e). The EPA contends that 6 months is enough time for a newly subject facility to begin using the methods required in § 98.233. This time period is consistent with requirements in the final subpart W ru le, in which we previously allowed the use of BAMM for the first six months of data collection to allow reporters newly subject to subpart W to comply. We are also broadening proposed missing data provisions in §98.235(f) to consider new “sources” rather t han “wells” as suggested by the commenter.

• The EPA has revised the proposed missing data procedures to provide more general procedures for emission sources that are measured quarterly or more often and for emission sources with annual measurement requireme nts . Thus, the missing data provisions now cover a wider range of measurements than initially proposed

. See Section

174II.C of the preamble to the final rule for further discussion regarding the missing data procedures in the final rule

• With respect to vent lines that cannot safely be measured or are inaccessible, we are finalizing many of the proposed revisions that will allow for the testing of these compressor vents without the use of BAMM . For example, we are clarifying that operators do not have to shut a facility down for the sole purpose to test a compressor in its non

- operating mode, but that the measurement must be made at the next scheduled shutdown that requires a compressor to be taken off

- line for planned or scheduled maintenance. We have provided for reporters to conduct a single annual as found measurement for manifolded compressors routed to a common vent, in lieu of a measurement for each individual compressor manifolded to the common vent. We are also allowing the use of optical gas imaging eq uipment for pre

- screening of emissions from blowdown valves on compressors in operating

- mode or standby

- pressurized

- mode and for isolation valves on compressors in not

- operating

- depressurized

- mode. If no emissions are observed, then the measurement value o f zero may be used and no further measurement is required. The option to use optical gas imaging equipment to screen for emissions, in addition to the current allowance for use of acoustic measurement device s , eases the burden on facilities with inaccessib le or unsafe

- to

- measure vents . Finally, for compressors routed to a flare, we are finalizing provisions to allow operators to calculate and report emissions with other flare emissions. In this case, reporters are no longer required to sample compressors ro uted to a flare individually. The revisions in this final rule resolve the technical and safety issues for which BAMM has been used in previous years
. See Section II.B.11 of the preamble to the final rule for additional information. Even though many of the proposed revisions that we are finalizing were intended to eliminate the need for BAMM, we have determined that there are certain data elements in the newly proposed calculation methods for which measurement systems may not be avail able. W e are , therefore, finalizing several revisions to the BAMM requirements to allow the short

- term transitional use of BAMM for reporters subject to these new requirements (e.g., for well venting for liquids unloading , for well completions and workover s , or for vents from manifolded compressors)

. See Section II.D.2 of the preamble to the final rule for a discussion of these changes

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Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EP A

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Comment: In the event that EPA nevertheless moves forward with the elimination of BAMM, Kinder Morgan strongly urges EPA to ensure that Subpart W’s missing data provisions apply to sources and cover c ase
- specific monitoring circumstances for which EPA has previously reviewed and approved BAMM requests. Such case

- specific circumstances include, but are not limited to, equipment and piping configurations that cannot be easily modified without incurring s ignificant expense and operational delays; unsafe access to compressor, tank and other

175equipment vents for which Subpart W requires measurement; and data gaps associated with downtime and malfunctions of continuous meters, including continuous flow meters. Unlike most other industries subject to the GHGRP, Kinder Morgan and other natural gas industry operators are required to conduct actual physical measurements of their equipment components. Response: S ee response to comment EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: It is not clear if revisions to the missing data section are intended to balance the elimination of BAMM

. Requirements for GHG estimates should provide flexibility for calculations, input parameters, and measurement methods based on defined data quality objectives and consistent appl ication of those objectives across source types, segments, and industries. Response: S ee response to comment EPA

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Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Co mpany (SoCal Gas) Document Control Number: EPA

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Comment: Elimination of the BAMM provisions will compromise the ability of Reporters to comply unless Missing Data provisions broadly address alternative a pproaches. In the Proposed Rule, the BAMM provisions are deleted and the Missing Data Provisions are significantly revised. Consequently, what is left of the Missing Data Provisions will be needed to address all BAMM requests previously approved by EPA, an d to broadly cover unforeseen future circumstances. For example, the revised Missing Data Provisions would have to be utilized when measuring emissions from compressor vent lines that cannot be safely accessed (e.g. vent lines that are elevated above high pressure pipelines and are not safe to access) or are technically infeasible to measure. Doing so may likely result in a level of measurement precision and accuracy that is less than ideal. Response: S ee response to comment EPA

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176Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: INGAA supports revisions to §98.235 (Missing Data). It is imperative that this section provides access to alternatives for measurement and monitoring. INGAA supports proposed revisions to §98.235 that address facility

- level, source

- level, and measurement and method circumstances that may result in missing data. As discussed in Comments 3 through 6 above, it is imperative that Subpart W include provisions that provide operators the ability to address unforeseen scenarios and measurement challenges. INGAA re commends clarifying revisions to §98.235 in Comment 6. With those revisions and with preamble or support document discussion to clarify potential implementation questions, INGAA supports the revisions to Missing Data provisions. Response: The EPA thanks t he commenter for their support of the proposed revisions to §98.235. S ee Section II.C of the preamble to the final rule for additional discussion regarding the missing data procedures in the final rule

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Commenter Name: Ritu Talwar Commenter Affiliation: Spectra Energy Corp Document Control Number: EPA

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Comment: EPA should clarify its definition of Missing Data to allow operators to utilize alternative methodologies to comply with reporting requirement s. It is imperative that EPA address all scenarios that have been addressed from 2011 through 2014 using BAMM requests. Response: S ee response to comment EPA

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Commenter Name: Karin Ritter Commenter A ffiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: The revised missing data procedures should not be promulgated as proposed

. Related to EPA’s proposed elimination of BAMM, EPA proposes to extensively modify the missing data procedures in §98.235. As proposed, the missing data procedures are confusing, unnecessarily burdensome, and not sufficient to provide the flexibility needed to enable compliance by the regulated i ndustry.

177Response: S ee response to comment EPA

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Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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Comment: Should BAMM be phased

- out, then reporters should be provided an alternate means of reporting data that cannot be safely or feasibly collected. EPA has communicated its intention to use the amended missing data procedures section in 40 CFR 98 .235 as a replacement for BAMM. While Williams agrees with this approach, we believe the amended missing data section lacks clarity. In 40 CFR 98.235(g), EPA should clearly communicate to reporters that data may be substituted for venting measurements that are not collected due to safety concerns or inaccessibility. Response: S ee response to comment EPA

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Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Company (SoCal Gas) Document Control Number: EPA

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Comment: SoCal Gas supports the proposed revisions to the Missing Data Provisions in §98.235 that address facility

- and source

- level measurement and data collection cir cumstances which may result in missing data. If Best Available Monitoring Methods (BAMM) provisions in §98.234(f) are removed from Subpart W, however, then it becomes imperative that Subpart W include missing data provisions which would enable operators to address unforeseen data collection complications and measurement challenges. Why is access to alternative methods and procedures for collecting data so essential and must be provided for Subpart W? Compliance with air quality regulations, including those that regulate criteria or hazardous air pollutants (e.g., NSPS and NESHAP), necessarily requires measurement, testing, or monitoring methods to demonstrate compliance. Sometimes, however, alternative measurement or monitoring procedures are needed, especia lly when circumstances beyond a facility's reasonable control prevent utilization of the standard measurement or monitoring methods. In the case of Subpart W, the Best Available Monitoring Methods (BAMM) in §98.234(f) provide access to alternatives for Sub part W measurements and other data collection requirements.

178Response: The EPA thanks the commenter for their support of the proposed revisions to §98.235. S ee response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: API is seriously concerned with the provision in §98.235(h) which directs the reporter to §98.236(bb) that requires reporting of information for “all measured and substitute values of a parameter, and the procedures used to substitute an unavailable value of a parameter per the requirements in §98.236(bb).” In turn, the provisions of §98.236(b b) requires reporters to report information that API views as inappropriate for a GHG reporting program and that constitutes overreach by EPA. In particular API objects to the following provisions of §98.236(bb):

• Provisions that require reporting of all information for “each individual missing data value used in a calculation”; that prohibit “Aggregation of missing data values within a component, well, sub

- basin, or basin” and that require reporting all information items for each temporal instance separately “If missing data is substituted for the same parameter in non

- consecutive periods during the calendar year, the information in paragraphs (bb)(1) through (bb)(5) in this section should be reported for each period separately.” This constitutes an inefficient set of requirements that creates unneeded burden on reporters. Response: After considering the proposed reporting requirements in light of the comments received and the reporting provisions in other subparts, we determined that revisions were needed to the proposed missing data reporting requirements. In this final rule, we are requiring reporting of the use of missing data procedures according to the general provision requirements in § 98.3(c)(8), except we are providing for the reporting of n umber times missing data procedures were used for an element that is not based on continuously monitored parameters. See Section II.C of the preamble to the final rule further discussion on the missing data reporting requirements

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: API specifically objects to the following information items required in §98.236:

17998.236 (bb) (3): The description of the unique or unusual circumstance that led to missing data use, including information on any equipment or components involved and any procedures that were not followed. 98.236 (bb) (5) The description of how the owner or operator will avoid the use of missing data in the future, such as mitigation strategies or changes to standard operating procedures. API views both of these provisions to be beyond any reasonable requirements for a GHG reporting program, a clear overreach of EPA’s aut hority, of no use to EPA or the reporter, and a substantial additional burden that is not warranted. API suggests the following modifications to the language in 98.236 (bb) to address these concerns. (bb) For any missing data procedures used, report the in formation in paragraphs (bb)(1) through (bb)(5) in this section for each individual missing data value used in a calculation. Aggregation of missing data values within a component, well, sub

- basin, or basin is not acceptable. If missing data is substituted for the same parameter in nonconsecutive periods during the calendar year, the information in paragraphs (bb)(1) through (bb)(5) in this section should be reported for each period separately. (1) The date(s) the missing data is used. (2) The equation(s) in which the missing data is used. (3) The description of the unique or unusual circumstance that led to missing data use, including information on any equipment or components involved and any procedures that were not followed. (4) The description of the p rocedures used to substitute an unavailable value of a parameter. (5) The description of how the owner or operator will avoid the use of missing data in the future, such as mitigation strategies or changes to standard operating procedures. Response: S ee r esponse to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 143
Com ment: Proposed Citation Reference: §98.236(bb), and (bb)(1), Proposed Rule Text:(bb) For any missing data procedures used, report the information in paragraphs (1) through (5) in this section for each individual missing data value used in a calculation. A ggregation of missing data values within a component, well, sub

- basin, or basin is not acceptable. If missing data is substituted for the same parameter in non

- consecutive periods during the calendar year, the information in paragraphs (1) through (5) in t his section should be reported for each period separately. (1) The date(s) the missing data is used.
A PI urges EPA to remove the phrase “Aggregation of missing data values within a component, well, sub

- basin, or basin is not acceptable. If missing data is substituted for the same parameter

180in non

- consecutive periods during the calendar year, the information in paragraphs (1) through (5) in this section should be reported for each period separately.” API objects to these provisions. Response: After consider ing the proposed reporting requirements in light of the comments received and the reporting provisions in other subparts, we have significantly revised the proposed missing data reporting requirements. In this final rule, we are requiring reporting of the use of missing data procedures following the general provision requirements in § 98.3(c)(8). In the final rule, the reporter is required to identify each data element for which a missing data procedure was used and the number times missing data procedures w ere used for that element. Depending on the data element, this may include reporting at the emission unit level without aggregation within a well, sub

- basin, or basin. However, the detailed information proposed to be reported at §98.236(bb)(1) through (5) are not being finalized. See Section II.C of the preamble to the final rule further discussion on the missing data reporting requirements

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference:§98.236(bb)(3), and (bb)(1), Proposed Rule Text: The description of the unique or unusual circumstance that led to missing data use, including information on an y equipment or components involved and any procedures that were not followed. API views this requirement to be beyond any reasonable requirements for a GHG reporting program, a clear overreach of EPA’s authority, of no use to EPA or the reporter, and a sub stantial additional burden that is not warranted. EPA should remove this requirement from the final rule. Response: The EPA is not finalizing the detailed information proposed to be reported at §98.236(bb)(1) through (5). See Section II.C of the preamble to the final rule further discussion on the missing data reporting requirements

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference:§98.236(bb)(5), Proposed Rule Text: The description of how the owner or operator will avoid the use of missing data in the future, such as mitigation strategies or changes to standard operating procedures.

181API views th is requirement to be beyond any reasonable requirements for a GHG reporting program, a clear overreach of EPA’s authority, of no use to EPA or the reporter, and a substantial additional burden that is not warranted. EPA should remove this requirement from the final rule. Response: The EPA is not finalizing the detailed information proposed to be reported at §98.236(bb)(1) through (5). See Section II.C of the preamble to the final rule further discussion on the missing data reporting requirements

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Commenter Name: Carrie B. Crumpton Commenter Affiliation: CONSOL Energy, Inc. Document Control Number: EPA

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Comment: The rule itself incorporates data collection and reporting requirements that go bey ond the requirements of a reporting program. This includes:

• Reporting a description of how the owner or operator will avoid the use of missing data in the future for each missing data value used in a calculation.

• Reporting the description of the unique or unusual circumstance that led to missing data use.

• Including information on any equipment or components involved and any procedures that were not followed for each missing data value used in a calculation. Response: The EPA is not finalizing the detailed information proposed to be reported at §98.236(bb)(1) through (5). See Section II.C of the preamble to the final rule further discussion on the missing data reporting requirements

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Commenter Name: V. Bruce Thompson Commenter Affiliation: American Exploration & Production Council (AXPC) Document Control Number: EPA

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Comment: AXPC and the Alliance believe that the missing data provisions which were added to the proposed rule are unreasonable to com ply with. Reporters under this rule have hundreds of thousands to millions of data points to gather and now report to comply with this rule. Given the sheer volume of information and inherent imperfection in data collection and storage systems there will a lways be a number of individual data elements that are going to be unavailable for some portion of time during the year. As such, it would be infeasible if not impossible to track and report on each missing data element to the level of detail that EPA is p roposing. While we do not object to reporting on the occurrence, dates, and data substitution methods employed we believe that doing this individually for each occurrence is unnecessarily burdensome. Generally, the same type of inadvertent and unavoidable data collection issues will affect several data elements and instances and it would be extremely time consuming and unbeneficial to have to

182report this level of detail. We also believe that these data collection errors and occasional failures are unavoidab le and object to the requirement to explain the unique circumstances that led to the missing data and the steps the operator will take to avoid future missing data. Examples of unavoidable data gathering errors and failures include loss of radio communicat ion of a SCADA system, loss of electricity, and data collection system wires losing contact due to natural conditions such as wind, precipitation, animal contact, heat, cold, or equipment vibration. In order to resolve this issue AXPC and the Alliance urge EPA to remove the requirement to report on individual missing data instances in §98.236(bb) and the specific requirements in §98.236(bb)(3) and (5). Response: The EPA is not finalizing the detailed information proposed to be reported at § 98. 2 3 6(bb)(1) th rough (5). See Section II.C of the preamble to the final rule further discussion on the missing data reporting requirements.
19
. 2 Provisions for newly acquired wells or sources
Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Asso ciation of America (INGAA) Document Control Number: EPA

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Comment: §98.235(f) should be revised to address all Subpart W sources and segments. §98.235(f) addresses a situation where a change (i.e., new w ell) occurs at a facility already subject to Subpart W and allows best engineering estimates in lieu of measured data for six months. INGAA strongly supports the concept addressed by §98.235(f), where a change at an affected facility is allowed to use best estimates for an abbreviated period. However, similar complications can arise for sources other than wells, and this section should be broadly applicable to all Subpart W affected segments and source types that are required to report. There are many scena rios where additions to an affected facility could result in complications similar to the well scenario addressed in the Proposed Rule. For example, compressors are a listed source type for T&S operations. A new compressor (i.e., additional or replacement capacity) could be added at a compressor station that reports under Subpart W. Since pipeline demand typically increases over the winter months, new capacity may be brought on

- line late in the year to accommodate the heating season. In this scenario, it ma y be difficult and overly burdensome to require measurements from newly commissioned equipment, and the logistics associated with scheduling and conducting a test do not warrant this level of effort for the minimal operation that would occur within the cal endar year. In this scenario, §98.235(f) should apply and the operator would likely use reporter emissions factors for emission estimates from the new compressor. Many similar scenarios can be envisioned for facilities already subject to Subpart W.
To addr ess changes that occur at existing facilities already subject to GHGRP reporting, §98.235(f) should be revised to accommodate all segments. INGAA recommends the following revision:

183(f) For the first six months of required data collection, facilities that a re currently subject to subpart W and that acquire a new source(s) listed in §98.232 may use best engineering estimates for any data related to those newly acquired sources that cannot reasonably be measured or obtained according to the requirements of this subpart. Response: The EPA agrees with the commenter and w e have expanded the provisions in §98.235(f) in the final rule to account for scenarios in which facilities have acquired new sources (rather than new well) from another facility that were not previously subject to subpart W. See Section II.C.2 of the preamble to the final rule for additional discussion responding to these concerns.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Numb er: EPA

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Comment: API contends that §98.235(f) should be applicable to newly acquired wells whether or not they were subject to Subpart W previously. Upon acquisition of new production operations compan ies need sufficient time to merge the data collection and reporting systems to ensure that the integrated data can undergo the required QA/QC and be certified for reporting. API suggests the following changes to §98.235(f) :

• (f) For the first six months of required data collection, facilities that are currently subject to this subpart W and that acquire new wells that were not previously subject to this subpart W may use best engineering estimates for any data related to those newly acquired wells that canno t reasonably be measured or obtained according to the requirements of this subpart. Response: The EPA disagrees that § 98.235(f) should be extended to new wells acquired from other companies that were previously subject to subpart W. Sources that were previously subject to subpart W should have the necessary sampling ports or monitoring equipment needed to comply with the measurement requirements in the rule. See Section II.C .2 of the preamble to the final rule for additional discussi on responding to this comment.

Commenter Name: Darrell R. Johnson Commenter Affiliation: Southern California Gas Company (SoCal Gas) Document Control Number: EPA

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Comment: §98.235(f) should be revised to address all Subpart W sources and segments, and cover both new and newly acquired equipment and operations

. §98.235(f) addresses a situation where a specific change (i.e., new well) occurs at an onshore production facility already subject to Sub part Wand allows best engineering estimates for any associated data that cannot reasonably be measured or obtained for the first six months. SoCal Gas strongly supports the

184concept addressed by §98.235(f) where an affected facility is allowed to use best e stimates for an abbreviated period after a change. However, complications associated with new equipment and operations are not limited to wells, therefore this section should be revised broadly apply to all Subpart W segments and emission sources that are required to report. There are numerous circumstances where new equipment and operations at an affected facility could result in complications similar to the well scenario in the Proposed Rule. For example, centrifugal and reciprocating compressors are list ed source types for transmission and storage operations. As natural gas demand typically increases over the winter months, new compression capacity may be brought on

- line late in the year at a transmission or storage facility subject to Subpart W. Under th ese circumstances, it would be difficult and overly burdensome to require vent measurements from newly installed compressors. The logistics and the level of effort associated with scheduling and conducting a test are difficult to justify for the abbreviate d operation that would occur towards the end of the calendar year. §98.235(f) therefore should apply and the operator should be allowed to use reporter emissions factors as best engineering estimates of emissions from the new compressor. Many similar situa tions can be envisioned for facilities already subject to Subpart W. In addition, this provision should apply to any newly acquired emission source, regardless of whether or not the source was previously subject to Subpart W. A similar level of effort is
n eeded to integrate newly developed and newly acquired equipment and operations into an existing reporting program. Further, obtaining all the acquired source data from the previous owner can take time, and depending on the source acquisition timing, may no t be available by the reporting due date. To address changes that occur at existing facilities already subject to GHGRP reporting requirements, §98.235(f) should be revised to accommodate all sources and segments and to cover both new and newly acquired eq uipment. SoCal Gas recommends the following revision: "For the first six months of required data collection, facilities that are currently subject to subpart Wand that acquire a new source(s) listed in §98.232 wells that were not previously subject to subp art W may use best engineering estimates for any data related to those newly acquired sources that cannot reasonably be measured or obtained according to the requirements of this subpart." Response: The EPA agrees with the commenter and w e have expanded t hese provisions in §98.235(f) in the final rule to account for scenarios in which facilities have acquired new sources from another facility that were not previously subject to subpart W. The EPA disagrees that § 98.235(f) should be extended to newly instal led sources or sources acquired from other companies that were previously subject to subpart W. See Section II.C.2 of the preamble to the final rule for additional discussion responding to these concerns.

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### 20.0 Best Available Monitoring Methods
20.1 Removal of BAMM requirements for 2015 and beyond

Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

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Comment: When EPA finalized Subpart W in November 2010, th e Agency limited BAMM to situations in which regulated facilities were unable to install the proper monitoring equipment. 2 These provisions allowed specific facilities to use BAMM until June 30, 2011, and any facilities requesting BAMM beyond that date wer e required to submit a written petition to EPA requesting an extension. 3 Importantly, no facility could request an extension beyond December 31, 2011, except “under extreme and unique circumstances, which include safety, or a requirement being technically infeasible or counter to other local, State or Federal regulations.” 4 Further, the facilities authorized to use BAMM were strictly limited to gas well workovers using hydraulic fracturing, gas well completions using hydraulic fracturing, and well testing and flaring. 5 Despite this intended provisional nature of the program, EPA expanded the availability of BAMM in subsequent revisions to Subpart W in September 2011. 6 These revisions allowed a presumptive extension of BAMM for all applicable facilities through December 31, 2011, expanded the availability of BAMM to the entire oil and gas sector, and substantially relaxed requirements for extending BAMM beyond 2011. 7 The changes transformed BAMM from a limited, transitional program to a more substantial fixture of Subpart W. Indeed, numerous facilities deployed these non

- standa rdized methods in reporting year 2012, during which 44 percent of onshore production facilities and 46 percent of natural gas transmission facilities utilized BAMM. 8 This widespread use of BAMM has created some difficulties in comparing data across facilit ies and understanding discrepancies between Subpart W and other GHG inventories and measurement studies. Given these concerns, we strongly support EPA’s proposal to eliminate all BAMM provisions in 40 C.F.R. § 98.234 by January 1, 2015. 9 The proposed rule recognizes that the oil and gas sector is the only industry

- specific subpart of the Reporting Rule that continues to permit the use of BAMM. 10 Moreover, eliminating BAMM will strengthen Subpart W reporting and help to promote data accuracy and comparabilit y across facilities. In proposing to phase out BAMM, the Agency has demonstrated that BAMM is no longer needed by closely examining past BAMM requests 11 and providing workable, standardized pathways to help ensure compliance. In particular, the proposal cr eates additional, standardized reporting methods for sources that frequently requested BAMM, including centrifugal compressors, reciprocating compressors, blowdown vent stacks, and combustion emissions. The proposed rule also expands the missing data proce dures and provides a compliance pathway for facilities that become subject to Subpart W in the future. 12 For example, for newly acquired wells, the proposed rule allows the use of best engineering estimates for any parameter that

186cannot be reasonably measu red or obtained for up to six months from the first date of Subpart W applicability. 13 EPA requested comments and rigorous technical evidence on specific contexts where operators believe unique and unusual circumstances would require the use of BAMM after its proposed elimination on January 1, 2015. In the event narrow circumstances exist where operators require even more flexible measurement methodologies than the ones EPA has proposed, such as to ensure worker safety, these flexibilities should be incorpo rated through a rulemaking effort rather than ongoing BAMM requests.
Footnotes:

2 75 Fed. Reg. 74,458, 74,471 (Nov. 30, 2010). 3 Id. 4 Id. 5 Id. 6 76 Fed. Reg. 59,533, 59,536

– 38 (Sept. 27, 2011). 7 Id. EPA modified the original rule’s language governing ex tension of BAMM past 2011 except under “extreme and unique circumstances,” and replaced it with considerably broader language, which permitted extensions under “unique or unusual circumstances such as data collection methods that do not meet safety, techni cal, or legal issues rendering them unable to meet the requirements of Subpart W.” 8 EPA, Petroleum and Natural Gas Systems 2012 Data Summary 17 (Oct. 2013), available at http://www.epa.gov/ghgreporting/documents/pdf/2013/documents/SubpartW

- 2012

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Summa ry.pdf. 9 79 Fed. Reg. at 13,404

– 05. 10 Id. at 13,405. 11 Id. at 13,404. 12 Id. 13 Id. Response: The EPA thanks the commenter for their support. See Section II.D of the preamble to the final rule for the EPA’s decision to remove existing BAMM provisions and to provide for short

- term transitional BAMM in 2015 for reporters that may need to obtain the necessary equipment to conduct measurements as required under the revised calculation methods in the final rule.

Commenter Name: Pamela Lacey Commenter Aff iliation: American Gas Association (AGA) Document Control Number: EPA

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Comment: EPA has requested comment on its proposal to remove the provisions in 40 C.F.R. section 98.234(g) that allowed the optional use of BAMM in unique or unusual circumstances. 98 Fed. Reg. at 13,404. BAMM was a helpful safety valve at the start of the Subpart W reporting

187program. It allowed reporters to cope with situations that did not fit neatly into the regulatory frame work or that were not clearly addressed in the rule. AGA believes that with the clarifications EPA has proposed for reporting emissions from natural gas distribution facilities, together with the minor clarifications we request in these comments, there sho uld be no further need to use BAMM to report greenhouse gas emissions after January 1, 2015 from natural gas distribution facilities. Response: The EPA thanks the commenter for their support. See Section II.D of the preamble to the final rule for the EPA’s decision regarding the removal of existing BAMM provisions and to provide for short

- term transitional BAMM in 2015 for facilities that may need to obtain the necessary equipment to conduct measurements as required under the revised calculation methods in the final rule.

Commenter Name: Kathleen McNeil Commenter Affiliation: Document Control Number: EPA

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Comment: I am writing in support of the proposal to remove the Best Available Monitoring Methods (“BAMM”) from Subpart W of the Greenhouse Gas (GHG) Reporting Rule (40 CFR 98). Replacing BAMM standards with explicit reporting requirements for petro leum and natural gas systems to comply with greenhouse gas rules will reduce transaction costs and improve compliance. Common criticisms of “best available” practices currently apply to the reporting rule, including the industry’s reliance on practices tha t are merely “good enough” or that do not work for certain situations. The reporting under BAMM standards have caused many problems, including missing data. Removing BAMM standards will greatly enhance the quality of the reporting, and importantly will gre atly enhance the consistency of the reporting. The proposed amendment that will allow the optional use of BAMM in certain circumstances for one reporting year is a fair compromise for companies to achieve the reporting necessary to meet the proposed standa rds. Increasing consistency will reduce transaction costs for reporting companies and garner more confidence in the Greenhouse Gas Reporting Program. The EPA’s Greenhouse Gas Reporting Program is a vital educational tool for making policy, business, and re gulatory decisions. Mandatory “reporting pushes companies to be more disciplined about their environmental performance, which, in turn, reduces their environmental risk.” The reporting regimen is critical for businesses to make decisions about their own en vironmental risks, and for government and the public to make decisions about the environmental costs that they expect companies, especially those working within the energy sector, to undertake. The Oil & Gas sectors in particular should have stringent obli gations to report and internalize the costs stemming from their production of greenhouse gases. The United Nations, through its climate chief, recently called on the oil & gas industry to transform their production to incorporate measures that would reduce carbon output or risk having to leave valuable fuel reserves unexplored. This move came in response to leading scientists warning that climate

188change will have a negative impact on food supplies, economic growth, and the causes of armed conflicts. The agr eement struck at the 2010 United Nations Climate Change Conference was to take action to avoid increasing the average global temperature by 2° Celsius above pre

- industrial levels; however, temperatures are going in the direction of breaching that ceiling. Despite encroachment on the upper limits of global temperatures, oil & gas companies assure that they are adequately addressing climate change through changes to their technology and extraction measures. Disclosure and mandatory reporting requirements are the primary and most important tools to ensure that the promises being made to the public are being actually enforced internally within the business. For those reasons, the missing data problem that existed before the proposed amendments to Subpart W were unacceptably hindering the public’s and government’s access to vital information about what is actually occurring in the oil and gas sector. Because of the recent push for oil and gas companies to take increased measures in order to comply with internation al agreements about reducing global temperatures, the need for accurate reporting is stronger than ever. To the extent that companies could take advantage of loopholes and confusion emerging from the use of BAMM, the information that is crucial to making p olicy determinations was not being accurately reflected. Therefore, the amendments to Subpart W are a needed change to make sure that companies are held to the standards they project. Response: The EPA thanks the commenter for their support. See Section I I.D of the preamble to the final rule for the EPA’s decision to remove existing BAMM provisions and to provide for short

- term transitional BAMM in 2015 for reporters that may need to obtain the necessary equipment to conduct measurements as required under the revised calculation methods in the final rule.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: To date, a number of INGAA comments have been addressed and Subpart W has improved significantly since the original 2009 proposal. For example: EPA has added measurement method flexibility and additional methods for some applications (but measurement methods remain an issue in some cases); EPA added default natural gas methane and CO2 composition for emission estimates from T&S and other segments downstream of processing; and EPA added emission factors for pneumatic device emission estimates. In addition, rule revisions provided technical corrections (e.g., correcting units and references to standard temperature and pressure in various equations) and improved rule clarity in some instances. However, fundamental issues remain for key T&S sources. Examples includ e:

• Access to alternative methods is a tenant to regulations, especially when measurement is required. Deleting the BAMM section may strand sources that become subject to GHG

18 9reporting, where unpredictable future events occur, or where vent measurement is u nsafe or infeasible. Response: The EPA is finalizing multiple revisions to the rule that address commenter concerns related to BAMM. See response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: As an alternative to the proposed byzantine procedures for use of the missing data provisions and reporting of information related to the use of missing data, EPA can simply retain an ongoing availability of BAMM for those instanc es where a reporter demonstrates a legitimate reason and need for such flexibility. Response: The EPA disagrees with the commenter that BAMM provisions should be provided on an ongoing basis. The EPA is finalizing the remov al of all prior BAMM provisions

. We are also finalizing multiple revisions to the missing data procedures and reporting requirements

. See Sections II.C and II.D of the preamble to the final rule regarding additional discussion responding to this comment

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Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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Comment: Williams objects to the proposed universal elimination of BAMM. Williams has historically used BAMM in cases where req uired monitoring activities posed a serious safety concern, or where such measurement was not possible. In most cases, Williams has employed BAMM for compressors with vents routed to flare, or for compressor vents that could not be safely accessed. In the absence of BAMM, Williams recommends that EPA revise the Missing Data section of Subpart W to allow the reporting of data that cannot be measured for the reasons noted above. Response: The final rule revisions address many of the concerns raised by the co mmenter (e.g. monitoring of compressor vents routed to a flare is no longer required). See response to comment EPA

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190Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: BAMM a nd Missing Data Regulations requiring measurement and monitoring must have access to alternative methods. INGAA strongly believes that the measurement requirements unique to Subpart W are integrally linked to the need for alternatives within Subpart W that may not be necessary for other GHGRP subparts with fewer or more simplistic measurement demands. However, the Proposed Rule would eliminate the Best Available Monitoring Methods (BAMM) section 8 in its entirety. This action may be reasonable if other a mendments (i.e., Missing Data revisions in §98.235) address the resulting void. As discussed in this comment and the three following comments, Subpart W includes more measurement and more complex measurement than other GHGRP subparts, so robust and thoroug h Subpart W missing data provisions are needed if the BAMM section is eliminated. It is common for air quality regulations, such as regulations that address criteria pollutants or hazardous air pollutants, to include measurement, testing, or monitoring to verify compliance. An integral component of measurement requirements is access to alternative methods. The GHGRP includes measurements for some emission estimates, but those are often based on processes already in place (e.g., fuel measurement, CEMS for ut ilities that have existing requirements under 40 CFR, part 75). Subpart W requires vent measurement for lines not previously measured, for processes and equipment not designed with measurement access considered. Following the established standard for air q uality regulations, access to alternative methods or procedures is integral when measurement is required. BAMM provisions in §98.234(f) provides access to alternatives for Subpart W measurements, and approaches that provide representative alternative data needed to perform Subpart W emission estimates. Examples of access to alternative monitoring, methods, and related QA/QC procedures are common in air quality regulations, and are often included in the general provisions. In addition, access to alternative emission standards or operating limits is typically provided. Several examples follow:

• National Emission Standards for Hazardous Air Pollutants (NESHAPs) in 40 CFR, Part 63 typically include compliance testing or monitoring and emission standards. Alternat ive options that are available include:

− §63.7

– Performance Testing Requirements: Includes major alternatives to test methods in §63.7(e)(2)(ii) and (f);

191− §63.8

– Monitoring Requirements: Includes reference to alternatives throughout, with details in §6 3.8(f);

− §63.6

– Compliance with standards and maintenance requirements: Includes alternative emissions and operating limitations in §63.6(g)

− §63.90 includes definitions related to major and minor changes in monitoring, test methods, etc. and includes e xamples of the wide array of alternatives that are accessible to sources subject to NESHAPs.

• New Source Performance Standards (NSPS) in 40 CFR, Part 60 typically include compliance testing or monitoring to ensure compliance with emission standards. Alterna tive options that are available include:

− §60.8

– Performance Tests: Includes alternatives in §60.8(b);

− §60.13

– Monitoring Requirements: Includes alternatives in §60.13(i)

– (j);

• Part 75 addresses Continuous Emission Monitoring Systems (CEMS) for utilities subject to the Acid Rain Program and includes Subpart E

– Alternative Monitoring Systems. This list shows that regulations that require compliance with emission limits provide access to regulatory alternatives for the emission standard, monitorin g, and performance tests. Subpart W should include this common regulatory paradigm, especially since the outcome for an inventory rule such as Subpart W has less environmental consequence than for an emission standard.
FOOTNOTE:

8 See 40 C.F.R. §98.234(f). Response: The EPA acknowledges that the provisions of NSPS and NESHAP allow facilities to request alternative monitoring and testing methods. However, the NSPS and NESHAP provisions typic ally require that specific monitoring methods be used (e.g. EPA Met hod 18 for gas compositional analysis) and they do not allow facilities to use alternative monitoring and testing methods without the method first being approved by the EPA

. The EPA has provided a great deal of flexibility in the methods allowed in subpar t W, such as certain provisions that allow the use of standard methods published by consensus

- based standard organizations and that allow the use of industry standard practice

. Given the great flexibility in the methods allow ed in the rule, the need for al ternative monitoring method provisions in the GHGRP are not the same as those for the NSPS or NESHAP programs

. The EPA has previously provided BAMM provisions to allow facilities time to prepare their facilities for meeting subpart W requirements. By the 2015 reporting year, facilities will have had four years to implement any necessary changes in equipment in order to fully comply with subpart W, which we have determined to be sufficient time to make any equipment modifications or installations. Additiona lly, we have made a number of revisions to the rule,

192such as allowance to monitor manifolded compressors, to address those cases where the use of BAMM was most often approved. There f ore, w e are removing the prior BAMM requirements in § 98.234(f) because we have determined that these provisions are no longer necessary to comply with the final rule. The EPA has provided multiple options for conducting measurements that provide flexibility to reporters, and we ha ve provided for short

- term transitional BAMM for facilities that may need to obtain the necessary equipment to conduct measurements under the revised calculation methods in this final rule. See response to comment EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: INGAA has consistently commented that measurement and BAMM are inextricably linked. INGAA has consistently commented that method flexibility and access to alternative methods is important, especially when measurement is required. Safety and access concerns for vent measurement have been consistent themes in INGAA comments, along with the fact that some measurement challenges cannot feasibly be remedied. Therefore, the alternative (e.g., use of emission factors for a sm all set of lines that cannot be measured) will always be needed for those cases. As long as measurement is required in Subpart W, access to alternatives is needed. As discussed in Comment 3, regulations commonly provide access to alternative methods, and t he use of BAMM has served that purpose for Subpart W. Compared to other GHGRP subparts, Subpart W requires more measurement, measurement of more lines, and access to existing lines that were not designed with measurement in mind. Thus, it is reasonable to retain BAMM sections in Subpart W while it may not be necessary for other industrial sectors. The importance of BAMM is evident by the rulemaking activity that has transpired since the original Subpart W final rule was published. Of the ten Subpart W rulem akings noted in Comment 1, several have dealt specifically with BAMM specifications and schedules, thus demonstrating the importance of BAMM for Subpart W compliance. INGAA has previously commented that the sunset of BAMM provisions could strand sources that subsequently become subject to GHG reporting (i.e., alternatives are not available to address initial implementation challenges) or where unpredictable future events occur. INGAA has commented that method flexibility is important so that progress (e.g ., new technology development) is not stymied. INGAA has commented that EPA should consider allowances if facility design precludes reasonable access to vent lines or condensate tank vents at a safe measurement location, and that criteria for approving alt ernatives should more fully recognize employee safety. These issues have been expressed repeatedly in INGAA written comments, in meetings, and in other communications with EPA.

193The thousands of measurements completed in 2011

– 2013 confirm the commitment o f INGAA members to completing measurements when feasible. In addition, the number of BAMM requests related to compressor vent measurement demonstrate that access to alternatives is imperative. In the current Subpart W rule, allowances for missing data are limited in scope, but revisions to §98.235 will likely address many scenarios previously covered by use of BAMM. However, it is not clear if those revisions comprehensively address scenarios evident based on implementation (and BAMM requests) to date. It i s imperative that alternatives are available when measurement is required

– whether via BAMM provisions (the current rule approach) or via missing data provisions (the apparent approach in the Proposed Rule). Response: See response to comment EPA

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Commenter Name: Ritu Talwar Commenter Affiliation: Spectra Energy Corp Document Control Number: EPA

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Comment: If BAMM is e liminated from Subpart W, m issing d ata m ust be r obust e nough to a ccount for m easurement, e quipment and n ew a sset e xceptions

. EPA has acknowledged in prior rulemaking the importance of BAMM for Subpart W compliance, which allows alternative measurement methods for sources subject to the Greenhouse Gas Reporting Rule. By eliminating BAMM the Proposed Rule will compromise compliance of impacted sources, specifically in instances when it is not reasonably feasible to obtain a required measurement or where direct measurement may be unsafe. BAMM was designed to ensure data qu ality and relieve unnecessary cost burdens while providing emission estimates. In other regulatory programs, EPA has elected to allow alternative compliance and monitoring methods. For example, New Source Performance Standards (NSPS) include alternative op tions for compliance and monitoring. BAMM serves that role for Subpart W. Spectra Energy uses BAMM in a limited, focused way, primarily to reduce safety risks associated with measurement in certain circumstances but also to provide information not otherwis e available, such as information from buried valves. Access to vent lines for measurement and other measurement challenges that cannot be feasibly remedied are situations that require and will continue to require alternatives. It is overly simplistic and u nrealistic to assume that by eliminating BAMM the Agency will have a more complete and improved greenhouse gas emissions estimate. However, should EPA ultimately decide to eliminate BAMM, a replacement for BAMM is required. Response: See response to comme nt EPA

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Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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Comment: Kinder Morgan supports INGAA’s comments opposing the removal of Best Available Monitoring Method (BAMM) as unwarranted at this time. In the Proposed Rule, EPA states that removing BAMM "would not add to previous burden estimates for subpart W reporters." 6 For this to be true with respect to the natural gas s ector’s Subpart W reporting obligations, modifications to the missing data provisions are necessary.
FOOTNOTE:

6 Proposed Rule at 13420. Response: See response to comment EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Need for BAMM: EPA requests comments on the circumstances that would require BAMM after January 1, 2015. As discussed in Comments 3 through 6, it appears that revisions to the Missing Data section address scenarios that have required BAMM or could require BAMM in the future. INGAA requests clarifications and revisions to missing data provisions in those comments. Dependent upon that outcome, some longstanding issues that have required BAMM c ould remain. In some cases, the scenario is not necessarily "unique or unusual," depending on how those terms are viewed. Example scenarios include: vent lines that are unsafe to access or infeasible to measure and do not have the ability to assess through

- valve leakage with an acoustic device; operating modes that are rarely employed (e.g., centrifugal compressor standard practice is to remain in standby mode) but nevertheless require measurement in shutdown, de

- pressurized mode; and, subject T&S facilitie s where a late year addition of a new source at the facility precludes the ability to gather data (e.g., complete vent measurements). These are a few examples and INGAA has commented at length on BAMM scenarios in previous comments (referenced in Comment 1 ) which can be reviewed for more detail. In addition, BAMM scenarios have been discussed many times with EPA. Those circumstances and

195examples have not changed. Therefore, inclusion of BAMM or an equivalent alternative in Subpart W (e.g., to address access to alternative methods) is imperative. Response: See response to comment EPA

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Commenter Name: Pamela Faggert Commenter Affiliation: Dominion Resources Services, Inc. Document Control Number: EPA

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Comment: Best Available Monitoring Methods (BAMM) and Missing Data : The pr oposed rule, if finalized, will remove the Best Available Monitoring and Measurement (BAMM) provisions of the rule, effective for the 2015 reporting year. BAMM allows companies to use Best Engineering Knowledge and Calculations to estimate emissions from s ources that are unsafe or inaccessible to measure directly. Future changes in operation or addition of equipment to existing facilities may cause them to exceed the MRR reporting threshold and could result in a circumstance where existing emission points d o not meet the Subpart W criteria. This situation would not necessarily be known until the facility was surveyed and may not allow enough time to resolve the situation before the monitoring deadline. Therefore, BAMM, or a replacement policy mechani sm, such as a robust missing data provision (discussed below), is needed in the final rule because changes to existing facilities may cause the facility as a whole to exceed the threshold for Subpart W reporting (25,000 tons per year of CO2e). Response: The EPA h as provided missing data provisions to address changes in operation or addition of equipment to existing facilities that may cause them to become subject to subpart W. Specifically, the final provisions in § 98.23 5 (d) provide for facilities that become newl y subject to this subpart W. These facilities may use best engineering estimates for any data that cannot reasonably be measured or obtained according to the requirements of the rule. Additionally, § 98.235(e) provides for facilities that are currently subj ect to subpart W and that acquire new sources from another facility that were not previously subject to this subpart W. See Section II.C of the preamble to the final rule for additional information.

Commenter Name: Kelly Guertin Commenter Affiliation: DTE Energy Document Control Number: EPA

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Comment: Access to alternative methodologies is imperative through Missing Data or BAMM provisions. Eliminating Best Available Monitoring Method (BAMM) alternativ es compromises the ability of affected sources to comply, especially where annual measurement may be

196precluded due to safety or operational concerns. DTE presumes that proposed revisions to the Missing Data provisions address, in its entirety, the signific ant void caused by eliminating BAMM. DTE recommends revisions to the Missing Data section to achieve this objective. DTE currently uses the BAMM provisions in order to eliminate safety concerns that come with obtaining measurements from specific sources of leaking and/or fugitive emissions including those from blowdown valves from compressor engines. Response: A s noted in the preamble to the proposed rule, the missing data procedures are not intended to replace BAMM. The EPA understands the safety and inaccessibility concerns raised by commenters, and we are finalizing many provisions to the monitoring requirements for compressors to address these concerns. These revisions include provisions to monitor manifolded compressor systems, provisions to use co ntinuous flow monitoring systems, allowance to use an acoustic leak detection device for blowdown valve leakage measurement, and provisions to use optical gas imaging equipment for compressor vent screening. See response to comment EPA

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Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Assoc iation of America (INGAA) Document Control Number: EPA

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Comment: When discussing the removal of the BAMM provisions for measuring compressor emissions, the TSD only addresses sampling from manifolded ve nts and fails to address unsafe to access and technically infeasible vent measurements for both individual and manifolded compressor sources. These are the primary issues requiring both historical and continued use of BAMM provisions. Response: By the 201 5 reporting year, facilities will have had four years to implement any necessary changes in equipment in order to fully comply with subpart W in a safe manner, which we have determined to be sufficient time to make any equipment modifications or installati ons. We are providing short

- term provisional BAMM in 2015 for reporters that may need to obtain the necessary equipment to conduct measurements as required under the revised calculation methods in the final rule, including manifolded compressors. See respo nse to comment EPA

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Commenter Name: Carrie B. Crumpton Commenter Affi liation: CONSOL Energy, Inc. Document Control Number: EPA

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197Comment: Use of best available monitoring methods (BAMM) should be allowed for newly acquired wells that had been previously reported by former owners, as well as wells that have never been reported. The level of effort required to include both categories into an existing program is essentially identical. If the applicable well data cannot be obtained from the previous owner, reporting delays and late submittals are inevitable. This language should be removed from the proposal. Response: The EPA disagrees that BAMM should be allowed for newly acquired wells that were pr eviously subject to subpart W. The reporting rule general provisions in § 98.4(h) provide for changes in owners and operators and provide that such owner or operator shall be responsible for the representations, actions, inactions, and submissions of the designated representative and any alternate designated representative of th e facility or supplier. As such, reporters are responsible for gathering data in a timely manner for acquired sources. Also, for wells acquired from companies that were previously subject to subpart W, any necessary sampling ports or other modifications wo uld have previously been made to the equipment to accommodate measurement. See Section II.C of the preamble for additional information.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: BAMM should be available in 2015 and beyond for newly acquired wells. Although EPA proposes to allow a six month period for use of engineering estimates for acquired wells that have not previo usly been reported under Subpart W, there is no reason not to extend this provision to acquired wells that were previously reported by another company. There is no distinction in the level of effort required to integrate a newly acquired well into an exist ing reporting program based on whether the well was previously subject to Subpart W or not

. In fact, because an owner of a newly acquired well may need to obtain information from the prior owner, the newly acquired well owner may need more time to obtain t he information from the seller. Response: See response to comment EPA

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### 20.2 Requests for transitional BAMM for 2015

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Nu mber: EPA

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Comment: Transitional BAMM should be available for a limited period following the final rule. API understands that EPA would like to remove all provisions regarding BAMM as part of the final r ule. At the same time, our collective experience with the GHGRP has demonstrated that industry will need adequate lead time to implement changes in the final rule. Consistent with

198past precedent and EPA’s desire to bring finality to BAMM, API proposes a re asonable six month timeframe for “Transitional BAMM” that would begin January 1, 2015 or the effective date of the rule, whichever is later. Given the limited time between the finalization of the rule and January 1, 2015, “Transitional BAMM” would allow th e reporters to read and digest the rule and to put all elements in place to ensure that all data collection can, in fact, go forward and other systems can be implemented to facilitate timely and accurate reporting. Response: The EPA agrees that short

- term transitional BAMM provisions are needed for emission sources that are subject to new monitoring or measurement requirements as part of these final revisions . In the final rule, the EPA is providing a short

- term (3 month) transitional BAMM period where BAM M may be used without submitting a formal request to the EPA. Reporters will also have the opportunity to request an extension for the use of BAMM beyond March 31, 2015; those owners or operators must submit a request to the Administrator by January 31, 20 15. The EPA is not providing transitional BAMM for these revised requirements beyond December 31, 2015. See Section II.D of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: API is not proposing that EPA should continue to allow BAMM indefinitely. Rather, consistent with EPA’s past pract ice, API and its members request that EPA provide reporters with a six

- month period of “transitional BAMM” that would begin January 1, 2015 or the effective date of the rule, whichever is later. This six

- month period is necessary to allow API members adequ ate and sufficient lead time to read and digest the rule once it becomes final, to provide time for facilities to put systems into place, and to accommodate what appears to be greatly expanded (and burdensome) measurement and reporting requirements in the proposed rule (discussed further below). Furthermore, extending “transitional BAMM” for six months will provide necessary flexibility to reporters and also accommodate inevitable issues regarding situations beyond the companies’ control which would require BAMM during this transitional period. Providing this six

- month lead time would accommodate the possibility that the terms as finalized in the rule will require further clarification or that reporters will find that it is more difficult than expected to de velop the required systems. API believes that this six

- month period is necessary and critical to resolving any additional issues that arise from the ultimate finalization of the rule. Response: See response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API)

199Document Control Number: EPA

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Comment: Transitional BAMM is Necessary. In the proposed rule, EPA states that “[i]n order to provide facilities with time to adjust to the requirements of the rule, Subpart W has provisions allowing the optional use of best available monitoring methods (BAMM) for unique or unusual circumstances. ” See 46 Fed. Reg. at 13404. EPA, however, in its next breath states that it is proposing to “ remove all provisions in 40 C.F.R. 98.234 for BAMM.” Id. According to EPA, although BAMM has been available and frequently used since 2010, removing BAMM at this time is appropriate because EPA expects that facilities would be able to comply with the monitoring and QA/QC methods required under Subpart W once the rule is final and effective because, according to EPA, “reporters with issues that were unidentified by the final rule will have adequate time to resolve these issues.” This unsupported statement, however, is unrealistic particularly where the timing and substance of the final rule is uncertain, the proposed rule adds additional new requirements that the rep orters must analyze, and in order to analyze these issues, the reporters must have some meaningful and reasonable lead time within which to understand the new finalized provisions and determine whether BAMM is needed.
EPA also states that its intent was th at BAMM would be a transitional program serving as a bridge to full compliance with the rule here reporters faced reasonable impediments. EPA believes that based on several years of the industry working with these reporting requirements, the facilities hav e “successfully transitioned so that they either no longer need to use BAMM or will not need to use BAMM if these proposed revisions are finalized.” Id. EPA also solicited comment requesting “strong technical evidence” for site

- specific unique or unusual c ircumstances that would require BAMM after January 1, 2015. Id. API is not taking issue with EPA’s general approach to phase out BAMM; however, given the timing of revisions to be implemented in this final rule and the compliance deadline of January 1, 201 5, a final six

- month extension of BAMM is critical and necessary. Experience has shown that BAMM has been critical to bridge the gap between the timing of EPA’s final rules and compliance obligations. EPA has allowed BAMM since 2010. Even in 2010, EPA stat ed that “EPA does not anticipate a need for Best Available Monitoring Measurements (BAMM) beyond 2011.” But, EPA found that further extensions were necessary in limited circumstances. In March 2011, BAMM was automatic, meaning that no requests for approval s were required. In 2012, BAMM remained available by submitting a Notice of Intent by December 31, 2011 followed by a BAMM request consistent with the regulations and BAMM would be automatically granted through June 2012 regardless of whether EPA ultimate ly approved the request. EPA also made clear that BAMM was available beyond December 2012 by submitting a BAMM request by September 20 of the year prior to the reporting year for which BAMM is being sought. See Subpart W: Best Available Monitoring Methods, Greenhouse Gas Reporting Program, March 2012. In 2013, BAMM continued to be available and, in fact, EPA revised the deadline by which BAMM requests must be submitted to the Administrator. See 78 Fed. Reg. 11585 (Feb. 19, 2013). API has found, over the co urse of implementing the GHGRP, that it can be more difficult than anticipated to develop processes for monitoring data or activities that have never been subject to federal or state mandated reporting. This is particularly so where various companies alrea dy

200may, for instance, have upwards of 8,000 separators and thousands of valves that must be monitored and where, for example, the proposed rule would sweep in hundreds (maybe thousands) of small storage tanks. Given the reporting burdens that already exist , the burdens that will occur under the proposed rule, and the additional burdens of the expansion of the measurement and data reporting requirements proposed in the rule, transitional BAMM is imperative. API members have relied upon Subpart W BAMM provisi ons to remedy unique or unusual circumstances during transitional periods. BAMM has been used to address safety issues, issues associated with the shutdown of plants, issues addressing rule interpretation questions, measurement flexibility issues, and tech nical deficiencies as Subpart W has undergone numerous revisions since its adoption in 2010. Given EPA’s further revisions in 2014, with a limited amount of lead

- time prior to January 1, 2015, now is not the time to eliminate BAMM from the GHGRP.
As noted above, API is not advocating for a permanent BAMM approach. Rather API believes that it is reasonable to provide a six

- month time frame (beginning the later of January 1, 2015 or the effective date of the Rule) to ensure that the reporters have resolved al l of their equipment issues and any other issues that may require further clarification. This is particularly true where, as described below, in this very rule EPA is proposing to remove BAMM while simultaneously expanding the measurement and data reportin g requirements, including changes to measurements or calculations from various types of equipment and events. Until the final rule has been issued, reporters will not be able to ascertain what is truly required, and it will not be clear whether BAMM is nee ded or not. Response: See response to comment EPA

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Commenter Name: V. Bruce Thompson Commenter Affiliation: American Exploration & Production Council (AXPC) Document Control Number: EPA

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Comment: AXPC and the Alliance appreciate that EPA developed BAMM for the initial implementation of the GHG Reporting Rule and did not intend to keep it indefinitely. However, for the same reasons stated above, We strongly belie ve that BAMM needs to be available for at least six months if the rule timing is pushed back and at least one year if the timing remains as proposed. This would allow reporters sufficient time to get the additional data collection, management, and reportin g systems in place for the newly required data elements. This will take a significant amount of time and effort and if EPA does not decide to extend BAMM on an applied for or presumptive basis then small operators without the resources to quickly implement the rule would be unfairly disadvantaged. Response: See response to comment EPA

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### 20.3 Dehydrators

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Third
- Party Dehydrators. Well

- pad owners/operators must report emissions under the GHGRP including emissions from dehydrators that are owned and operated by third

- party companies. Thus, the GHGRP ina ppropriately requires well

- pad owners/operators who must report to EPA to obtain, report, and certify information regarding emissions from an independent third

- party source

-- namely, the gathering system operators. In practice, however, the well

- pad owner /operator has no ability to measure the emissions from the third

- party dehydrators, has no mechanism or ability to QA/QC the information that the third

- party provided, and has no ability to ensure that the third

- party will provide timely emissions data to enable reporting. The GHGRP thus puts the regulated industry in an impossible position of having to report and certify information over which it lacks direct control. In past practice, BAMM has been used to overcome these issues. As described further below in section C and as previously provided to EPA [see 3rd Party Dehydrator

- Issues and Reporting Alternatives. Follow

- up from discussions with EPA on September 12, 2013. EPA Issue Tracker #18, September 26, 2013], there are various means to correct the rul e that provide EPA with high quality data without creating an impossible and infeasible compliance burden on the regulated industry that EPA should adopt in the final rule. Response: Subpart W reporters know what information is needed for their annual rep orts. If reporters elect to use third

- party vendors for certain services, the information needed for the annual reports may be specified in the third

- party contract or agreement to ensure the necessary information is provided. Additionally, as articulated in the preamble to the Final Mandatory GHG Reporting Rule (“Final GHGRR”), (40 CFR part 98) (74 FR 56260), the preamble to the final 2010 Subpart W rule (75 FR 74458), Vol ume 9, Legal Issues , of the Mandatory GHGRR: EPA’s Response to Public Comments (September 2009; available at http://www.epa.gov/ghgreporting/documents/pdf/2009/Volume9

- RTCLegalIssuesRTC

FINAL.pdf ) , and Vol ume 9, Legal Issues , of the Mandatory GHGRR Subpart W

- Petroleum and Natural Gas: EPA’s Response to Public Comments ( November 2010 ; available at http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart

- W_RTC_part2.pdf ) , the scope of Section 114 is quite broad and applies beyond persons who own or operate an emission source or who are otherwise subject to regulation under the CAA. I ts purpose extends to the collection of information for “carrying out any provision” of the Act (emphasis supplied). We note, however, that subpart W does not require a contractor or third party to report emissions; that responsibility lies with the owner or operator of the applicable subcategory and industry sector. Section 114(a)(1) provides that the Administrator may require any person who owns or operates an emissions source to collect and provide relevant CAA information to EPA. As explained, the owner or operator is in the best position to collect and report that information to the Agency.

202The fact that emissions might be generated by equipment or processes owned by a party independent of the owner or operator of a particular facility is not determinat ive. The owner or operator has ultimate responsibility for the facility and the obligation and responsibility to assure that the required information can be collected through legally binding contracts, leases, or other agreements. This position that an own er or operator, through contract or other third

- party agreement, cannot otherwise shirk CAA responsibility has long been that of the Agency (see authorities cited below). Although the GHGRR is not delimited by other CAA programs such as NSR or Title V, an d the EPA deems it inappropriate to tailor the provisions of the reporting rules to any specific program, we have explained this concept numerous times in the context of NSR or Title V which is here instructive and of precedential value. The premise underl ying this position lies in the notion that the owner or operator has the power to control, the “...power of authority to guide, manage, or regulate the pollutant

- emitting activities of those facilities....” See, Guidance for Major Source Determinations at Mili tary Installations under the Air Toxics, New Source Review, and Title V Operating Permit Programs of the Clean Air Act in Memorandum for Major Source Determinations for Military Installations, John S. Seitz, Director, Office of Air Quality Planning and Sta ndards, August 2, 1996. Therein it is explained that because the contracting entity can control the contract operator’s performance through contract terms, contract

- for

- service activities are considered part of a source. Likewise, the Agency has flatty sta ted its policy that “temporary and contractor

- operated units [must] be included as part of the source with which they operate or support” and “that there are no provisions in title I or title V of the Act, or in regulations developed pursuant to them, for excluding contracted or temporary operations in defining major sources.” Letter from John S. Seitz to Lisa J. Thorvig, Division Manager, Minnesota Pollution Control Agency, November 16, 1994. The underlying rationale for including sources over which an own er or operator exercises control in making major source determinations in the permitting context is thoroughly explained in 1995 guidance, Letter from William Spratlin, Director, Air, RCRA, and Toxics Division, EPA Region VII, to State and Local Air Direct ors, September 18, 1995. Further, as explained in Section V of the preamble of the 2009 final part 98 (74 FR 56355), all reporters must select a designated representative (DR) who is responsible for certifying, signing, and submitting all submissions to EP A. This provision provides flexibility to the owners and operators to choose any individual, employee or non

- employee, to represent them, while ensuring EPA has one accountable point of contact. As explained in the preamble to the final part 98, the high l evel of public interest in the data collected, as well as its importance to future policy, warrants establishment of a high standard for data quality and consistency and high level of accountability for reported data. The DR provisions and certification re quirements help ensure the standard for high quality data and consistency is met. The DR provisions are crafted similarly to the provisions of the Acid Rain Program (ARP), 40 CFR part 72 and EPA has found that this approach provides a high degree of both d ata quality and consistency and accountability. Similar comments were made about the data coming from multiple owners and operators and the concerns about the certification of those data upon promulgation of the ARP and the 2009 final GHG reporting rule to which we responded, and for which responses are summarized. We have attempted to provide maximum flexibility while ensuring accountability. For integrity of the program, one representative of the owners and operators must report for important reasons.

203Doi ng so ensures the accountability of owners or operators by, inter alia, reducing the likelihood of inconsistent submissions by a facility. Interposing another person or party between the facility and the Agency would dilute the DR’s responsibility and in e ffect create multiple DRs for the facility. Additionally, leaving the ultimate responsibility of submission with the designated representative has the salutary effect of clarifying that the DR should be aware of all submissions and should inquire of the pe rsons with personal knowledge of the information in those submissions. The DR has the flexibility to delegate duties, such as the preparation of submissions, but retains the ultimate responsibility to sign and certify all submissions. (See, 58 FR 3590, 359 8, January 11, 1993.) Furthermore, we believe that the commenter has misinterpreted the Part 98 certification provisions which simply require the DR to make “appropriate inquiry” and certify to the best of his or her knowledge, §98.4(e)(1), however ultima te responsibility rests and must necessarily rest on him or her. The DR may provide in contracts, leases, or other agreements with third parties that true, accurate, and correct reporting information must be provided to the DR in a timely fashion. If the t hird party fails to provide timely, true, accurate, or correct information to the DR, then the DR has recourse contractually, or otherwise, on the third party

. See Section II. C of the preamble to the final rule for additional discussion responding to this comment.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: EPA Must Amend the Third
- Party Dehydrators Reporting Requirements. The GHGRP requires that well

- pad owners/operators report emissions from dehydrators located on a single well

- pad including dehydrators owned and operated by third

- party companies. Thus, in an unexplainable requirement unique in the GHGRP to this specific issue, EPA requires owners/operators of the well

- pad to obtain information from third

- party dehydrator owners/operators regarding emissions, inputs to the dehydrator models, and outputs from the dehydrator models and report these third

- party emissions and other required information, as well as maintain such third

- party data for record

- keeping. Additionally, as part of the reporting obligations, the designated representative for the reporting owner/operator is required to certify the accuracy of third

- party emissions and information data. API vehemently objects to EPA’s approach to Third

- Party Dehydrators for a number of reasons. First, under the GHGRP, EPA is requiring the wrong party

— the well

- pad owners/operators

— to obtain the emissions information that EPA is requesting. For activities performed by third

- party service providers, EPA incorrectly takes the position that it should not be burdensome for the well

- pad owners/operators to seek, obta in, and certify emissions information from third

- party contractors. EPA simply ignores that well

- pad owners lack legal mechanisms and the ability to require the third

- party gathering company to provide the emissions information to the owners/operators in t he first place. Additionally, the well

- pad owners/operators have no mechanism or ability to QA/QC data collected by another company or to certify the information provided by a third

- party dehydrator owner/operator.

204It is simply not possible or prudent for the owners/operators to “certify”

— as EPA requires

— that the data is correct because the owners/operators do not collect the data. It would be very inappropriate, in fact, to certify third

- party data as correct in a government run system which could subject the companies to enforcement actions and criminal claims under 18 U.S.C. 1001 and other provisions. Where there is no EPA rule requiring the third parties to report emissions from their equipment, but instead the well

- pad owners/operators must do so, it is beyond inappropriate for owners to, in fact, certify the “accuracy of the emissions and information reported” based on third party information that it may or may not be able to obtain. The information from the third parties is not first

- hand, and where AP I member companies cannot use their QA/QC processes, if the well

- pad owners/operators in fact certified the accuracy of the emissions and information reported, they could be subjecting themselves to civil or criminal sanctions or criminal liability for mak ing inaccurate statements within the jurisdiction of the federal government [API also believes there could be a serious Due Process issue with requiring an entity to certify information from third parties under the potential penalty of criminal liability. Due Process includes liberty preserved from deprivation without due process and encompasses freedom from bodily restraint and punishment. See Matthews v.Eldridge, 424 U.S. 319, 335 (1976)]. It is arbitrary and capricious for EPA to require one party to obt ain, report, and certify data that relates to the operations of an independent third party. This is simply an area that the GHGRP gets entirely wrong, and EPA must address. Until EPA recently announced that it is proposing to remove all BAMM provisions, re porters have been relying on BAMM to ensure appropriate reporting in this area
. The difficulties and obstacles

— if not impossibility

— of obtaining reliable and timely data from the intermediary companies cannot be overstated. EPA should not impose this data collection requirement on companies that do not and cannot collect the data themselves. EPA, on the other hand, can propose that these reporting requirements apply to the third

- party entities that maintain the information on the emissions which could lead to better and more complete data. Moreover, API also has provided specific language and options to EPA in an effort to reconcile these issues and enable EPA to obtain high quality data without creating an impossible, arbitrary and capricious burden on the well

- pad owners and operators. We have attached proposed language that was provided to EPA in September 2013 that would enable EPA to get full and accurate information on third

- party dehydrators without subjecting owners/operators to the impossible reporti ng burden EPA is imposing here. One of API’s suggestions is for EPA to modify the rule to include an approach similar to what is used for small dehydrators where the well

- pad owners/operators would be required to report the number of dehydrators with annua l average daily throughput greater than or equal to 0.4 MMCSFD and less than 3.0 MMSCFD. We remain willing to work constructively with EPA toward solutions that would enable EPA to realize its interests in obtaining data without subjecting industry to an infeasible and unacceptable burden. Response: See response to comment EPA

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- A2, Excerpt 12 and Section II. C of the preamble to the final rule for the EPA’s response to this comment.

205Commenter Name: Jeff Applekamp Commenter Affiliati on: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number: 18
Comment: Third party dehydrators: GPA member companies own and operate dehydrators at onshore petroleum and natural gas production fac ilities. The proposed rule continues to require production facility owners/operators to report third party dehydrator emissions. As previously discussed with EPA, this requirement is problematic for both the dehydrator owner/operator and the production fac ility owner/operator. GPA therefore supports API’s comments regarding third party dehydrators. Response: See response to comment EPA

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- A2, Excerpt 12 and Section II. C of the preamble to the final rule for the EPA’s response to this com ment

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 95
Comment: Proposed Citation Reference for Dehydrators: §98.236(e)(1)(iii), P roposed Rule Text: Dehydrator feed natural gas water content, in pounds per million standard cubic feet. Proposed Citation Reference for Dehydrators: §98.236(e)(1)(iv), Proposed Rule Text: Dehydrator outlet natural gas water content, in pounds per million standard cubic feet. Proposed Citation Reference for Dehydrators: §98.236(e)(1)(vi),Proposed Rule Text: Dehydrator absorbent circulation rate, in gallons per minute. Proposed Citation Reference for Dehydrators:§98.236(e)(1)(xii), Proposed Rule Text: Pressu re of the wet natural gas, in pounds per square inch gauge. Proposed Citation Reference for Dehydrators§98.236(e)(1)(xvii), Proposed Rule Text: Whether any dehydrator emissions are vented to the atmosphere without being routed to a flare or regenerator fir ebox/fire tubes. This information is extremely difficult to collect from owners/operators of third

- party dehydrators. This issue also applies to some of the current reporting requirements for dehydrators, such as the temperature of the wet gas.
Well

- pad ow ners/operators have been utilizing BAMM to overcome these issues and enable reporting of 3rd party dehydrators, but EPA is removing this option. API urges EPA to revise §98.233(e) to allow the use of a default emission factor for mid

- sized dehydrators that are owned/operated by third parties.

206Response: At this time, we are not including default emissions factors for glycol dehydrators with a natural gas throughput of 0.4 million standard cubic feet or greater. See response to comment EPA

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Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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Comment: Williams strongly encourages EPA to adopt the emission factors, 311,950 scfy of methane and 13,643 scfy of carbon dioxide, previously submitted by API to the Agency in September 2013. These CO2 and CH4 emission factors were developed for mid

- size dehydration units that fall between 0.4 MMSCFD and 3.0 MMSCFD. Adoption of these emission factors would greatly simplify the reporting process for producers, and third

- party owner/operators (like Williams) who provide the emiss ions information to producers. Adoption would also allay producers’ concerns over certifying emissions based on operational data collected, and calculations performed and supplied by the third party owner/ operators. The proposed emissions factors were con servative values and resulted from: (1) an extensive review of dehydrator data from more than 1,800 affected dehydration units over two years; and (2) the scaling of mid

- size to small dehydrators, for which emission factors developed by EPA already exist. Should these emission factors not be adopted we recommend that BAMM continue to be allowed for these units due to the difficulties encountered by producers in obtaining, and subsequently reporting, this information. Response: At this time, we are not inc luding default emissions factors for glycol dehydrators with a natural gas throughput of 0.4 million standard cubic feet or greater. See response to comment EPA

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207

### 21.0 General Revisions to Reporting Requirements (including addition of new reporting elements)

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 24
Comment: EPA Should Not Finalize the Proposed Expansion of Measurements and Reporting Requirements in the Proposed Rule. The proposed rule, if finalized as proposed, would greatly expand the measur ements and reporting requirements from the existing GHGRP. First, under the proposed rule, EPA expands the definition of well type combinations for completions and workovers with hydraulic fracturing to include with and without flaring. This requirement do ubles the measurement and reporting requirements for Subpart W reporters. Second, the proposed rule expands the definition of well type combinations for workovers to include with and without reduced emission workover. This provision singlehandedly may quad ruple the measurement and reporting requirements. Third, the rule expands the requirements to report emissions for stuck dump valves to tanks with a throughput that is less than 10 bbls per day. These proposed new measurements and reporting requirements go beyond the authority under CAA Sections 114 and 208. EPA’s use of Section 114 historically has been properly limited to issuing Information Collection Requests (ICRs). ICRs have been limited to collecting data from specific sources over a discrete period of time usually relying upon existing data or a subset of the universe of sources, or both. Section 114, however, is not typically used to justify an economy
- wide, on

- going reporting rule requiring all affected entities to submit data annually with new, on erous, and ever

- changing monitoring and measurement processes. Furthermore, regarding Section 208, as EPA has expressly acknowledged, the rule was proposed in response to the 2008 Consolidated Appropriations Act, which provided limited funding, did not gra nt EPA any broad regulatory or enforcement authority, and limited the proposed rule to the reporting of greenhouse gas “emissions.” EPA in this proposed rule goes beyond its limited CAA authority, resulting in a proposal that would be arbitrary and caprici ous if finalized. For example, many of the new elements that EPA has inserted into the proposed rule simply do not address actual “emissions.” EPA’s authority is limited to addressing actual emissions. In the context of a the greenhouse gas reporting rule, CAA Section 114 cannot be relied upon to allow EPA to seek information about issues that are not directly related to the reporting of emissions . The expanded provisions in the proposed rule, however, erroneously request that members report a significant a mount of information that extends beyond the requirement of an emissions reporting program. For example, these expanded reporting requirements include:

• provisions requiring reporting the “Compressor power rating (hp)”; the year the compressor was installed , the compressor model name and description, and date of last maintenance shutdown for centrifugal and reciprocating compressors;

208• provisions requiring a description of how the owner or operator will avoid the use of missing data in the future for each missing data value used in a calculation that led to missing data use;

• a provision requiring reporters to describe the unique and unusual circumstances that led to missing data use;

• provisions requiring that reporters include information on any equipment o r components involved and any procedures that were not followed for each missing data value used in a calculation; and

• provisions requiring reporters to develop, collate, and report voluminous new items unrelated to emissions quantification and reporting i n §98.236(aa). API urges that EPA not adopt these arbitrary and capricious expansions particularly where the onerous reporting requirements do not facilitate the reporting of greenhouse gas emissions but instead seek general information regarding equipment and/or components or the structure of the oil and gas production sector and natural gas supply chain. These elements importantly, are not related to the required reporting of emissions data. Because these issues are beyond the scope of CAA Sections 114 an d 208, EPA lacks authority and API members should not have to bear the burden of measurements and reporting requirements that are not tethered to actual emissions as required under the CAA. Response: The EPA disagrees with the commenter that the proposed elements are beyond the authority of the EPA under CAA Section 114. However, we have reviewed the data reporting requirements and have made revisions to address several of the commenter’s concerns. For example, we significantly revised and limited reportin g associated with the use of missing data procedures. We have removed certain reporting requirements, such as model name and description for compressors. Also, the final rule revisions clarify that emissions due to gas

- liquid separator liquid dump valves n ot closing properly do not need to be calculated or reported for tanks with throughput less than 10 bbl/day. We are retaining the proposed delineation between reduced emission completions/workovers and the general reporting requirements in §98.236(aa) with minor revisions. See Section II.E.2 of the preamble to the final rule for further information regarding the final reporting requirements

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: EPA is seeking information that is not related to a reporting program. T he information that the proposed rule would require extends beyond the requirements of a reporting program by seeking information that does not address emissions but seeks ancillary information regarding, among others, compressor ratings, dates that compressors were maintained, reporting about how owners/operators will avoid using missing data in the future, and reportin g a description of the unique or unusual circumstance that led to missing data use. This overreach is

209particularly egregious in the reporting requirements at §98.236(aa) where it appears that EPA is attempting to use the GHGRP as a vehicle to construct a v ery detailed and comprehensive profile of the oil and gas production sector and the entire natural gas supply chain. The majority of the data/information elements required to be reported under §98.236(aa) are not related to emission quantification and repo rting and where they are related, they are required to be reported in the sections detailing reporting elements for each source type and hence redundant in §98.236(aa). A detailed discussion of these reporting elements and API’s objections can be found bel ow in the technical comments. Response: The EPA has determined that the data elements §98.236(aa) are useful for the verification of existing data. For example, production, capacity, or operational information may be used to normalize the data collected a nd improve our characterization of the emissions sources. Therefore, the EPA is finalizing these reporting requirements as proposed, with minor clarifications. See Section II.E.2 of the preamble to the final rule for further information regarding the final reporting requirements

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 71
Comment: EPA should reconsider new reporting requirements. Numerous data elements have been arbitrarily added, are not needed to calculate GHG emissions, and will add unnecessary burden for reporters. The Proposed Rule significantly increases the number of data elements to report under §98 .236. Although the preamble includes confidentiality determinations, and a docket memo tabulates the changes, EPA has not explained or justified the need for these data elements. As discussed in Comment 9, the new reporting requirements increase costs, and EPA should justify its decision for each data element added to §98.236. If INGAA understood EPA’s objective for adding the data elements, it is possible that specific feedback on various data elements could be provided. A partial list of data elements add ed for T&S sources that should be reconsidered and justified if included follows:

• For transmission storage tank vent stack, whether scrubber dump leakage is occurring for the underground storage vent

– §98.236(k)(l)(iii) ; see Comment 18 regarding the need for clarification;

• Average time surveyed components were found leaking and operational

– §98.236(q)(2)(iii);

• Average upstream pipeline pressure, psig

– §98.236(aa)(4)(iv);

• Average downstream pipeline pressure, psig

– §98.236(aa)(4)(v);

• Quantity of gas injected into storage

– §98.236(aa)(5)(i);

210• Quantity of gas withdrawn from storage

– §98.236(aa)(5)(ii);

• Number of compressors

– §98.236(aa)(4)(ii);

• Total compressor power rating for all compressors combined, HP

– §98.236(aa)(4)(iii);

• Total storage capacity for underground natural gas storage facilities

– §98.236(aa)(5)(iii). Response: The EPA has determined that the data elements in §98.236(aa) are useful for the verification of existing data. These data also improve our characterization of the emissions s ources. Therefore, the EPA is finalizing these reporting requirements as proposed, with some clarifications. See Section II.E.2 of the preamble to the final rule for further information regarding the final reporting requirements

.

Commenter Name: V. Bruc e Thompson Commenter Affiliation: American Exploration & Production Council (AXPC) Document Control Number: EPA

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- A2 Comment Excerpt Number: 2
Comment: Additionally, many of the added data elements that are proposed to be gathered a nd reported are not related to the emission calculations and should not be part of this GHG emissions reporting rule. For instance, EPA has added many data elements to compressor reporting such as engine horsepower, installation date, model name and descri ption, and date of last rod packing replacement. While these are clearly not within the scope of emission reporting, there are also other data elements that are burdensome to manage and report such as software simulation package used and associated inputs. These models are often run outside of the data management system and the inputs not available for subsequent reporting without making large modifications to the emissions data management system. AXPC and the Alliance requests that EPA reconsider the addition of data elements to report in this rulemaking, particularly those that do not pertain to emission calculations. We also urge EPA to reevaluate the man

‐ hours that will be required to implement the proposed data additions and changes to calculation methodologies in determining compliance and implementation dates. Response: The EPA has evaluated the commenter’s concerns. W e have revised the reporting requirements based on our review of the comments received and have removed the reporting requirements for the year the compressor was installed and the model name and description of the compressor. We also revised the proposed “compressor power rating” element to clarify that this reporting element is the “power output of the compressor drive r ”

. We also r eplaced the reporting requirement for the date of the last maintenance shutdown with a simple indication of whether the compressor had a scheduled depressurized shutdown during the reporting year. See Section II.E.2 of the preamble to the final rule for ad ditional response to this comment. Regarding the additional reporting requirements of inputs to software simulation packages, these data elements are being collected to assist in verification of the reported emissions data. Reporters should currently maint ain inputs of the software as part of existing reporting and recordkeeping requirements as required in § 98.3(g) (2 ). Therefore, it is our determination that

211reporters should have access to and be able to report this information in their reporting year 2015 submissions. Regarding the impacts of the reporting requirements in the final rule, see Section IV.B of the preamble to the final rule.

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Comment: Revisions to §98.236(aa): EPA is proposing to require reporting additional specific information for each applicable industry segment. API has serious concerns with the reporting requirements i n 98.236 (aa) in terms of the relevance of the information for quantifying emissions, the lack of clarity in some item requirements, the substantial burden associated with developing this information for reporting. Response: The EPA has determined that th ese data elements in §98.236(aa) are useful for the verification of existing data and for improving our characterization of the emissions sources. Regarding the burden associated with collecting the data reported, see Section IV.B of the preamble to the final rule.

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Comment: API has no comments regarding items (I) and (J) (K) If an oi l sub

- basin, report the average GOR of all wells, in thousand standard cubic feet per barrel. (L) If an oil sub

- basin, report the average API gravity of all wells. (M) If an oil sub

- basin, report average low pressure separator pressure, in pounds per squar e inch gauge. I tems (K) thru (M) are reported under §98.236(j) where they are relevant to calculation and reporting of emissions. Requiring reporting of these items as proposed in §98.236(aa)(1)(ii) is either not related to emissions quantification and rep orting and hence not within the purview of the GHGRP or redundant reporting which should be eliminated. Response: First, the EPA notes that these are not new reporting requirements. These reporting requirements were previously housed in §98.236(e) , but have been moved to the general sub

212basin reporting section proposed at §98.236(aa)

. Second, we disagree that these reporting elements are completely duplicative. If an oil well recovers all associated gas, then the reporting requirement for gas

- to

- oil rati o proposed at §98.236(m)(4) would not be applicable. Reporting of API gravity and separator pressure are only required when Calculation Methods 1 or 2 are used and then the values are to be reported separately by calculation method. Finally, it is convenie nt to have this general information provided together with other general sub

- basin information. For these reasons, we are finalizing these reporting requirements as proposed

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Insti tute (API) Document Control Number: EPA

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Comment: (2) For offshore production, report the quantities specified in paragraphs (aa)(2)(i) through (aa)(2)(iii) of this section. (i) The quantity of gas prod uced from the offshore platform in the calendar year for sales, in thousand standard cubic feet. (ii) The quantity of oil produced from the offshore platform in the calendar year for sales, in barrels. (iii) The quantity of condensate produced from the off shore platform in the calendar year for sales, in barrels. Again, API does not understand the relationship between emission quantification and reporting and the data required to be reported in §98.236(aa)(2)(i) thru (ii). This appears to be another instanc e of using the GHGRP as a vehicle to collect data EPA believes it may want that is not appropriate for an emission reporting program and overreaches EPA’s authority. Items §98.236(aa)(2)(i) thru (ii) should be stricken from the rule.
Should EPA retain thes e items, API has two issues with proposed changes to the reporting requirements for offshore production. First, offshore production facilities in Gulf of Mexico Outer Continental Shelf (OCS) waters or State jurisdictional waters in the Gulf of Mexico often are not set up as a stand

- alone production facility, with the entire production process from extraction from the seafloor to the custody transfer meter being housed on one discrete structure. Instead, shelf facilities can function in a web

- like formation, with individual platforms, that are not bridge

- connected, supporting different phases of the production process. The last step in the process is for the oil and gas to be transferred to a transportation pipeline, which typically occurs on a host facility at the point of custody transfer. The volume of oil and gas transferred to a pipeline after final processing is metered for purposes of reporting custody transfer volumes to regulatory, internal, and external stakeholders. Because processing of the oil and gas can occur in several stages on multiple platform structures connected solely by in

- field non

- custody transfer pipelines, it would be difficult to assign an accurate “sales” or “custody transfer” volume to these intermediary facilities that are not equ ipped with a custody transfer meter. For revenue

213allocation purposes, oil and gas volume allocation is based on well test data and the custody transfer metered volumes at the host facility, which typically receives oil and gas from several upstream interme diary structures. Therefore, because “sales” or “custody transfer” volumes are not required on an individual facility basis, but rather on an individual well basis, for revenue allocation reporting purposes, assigning such a volume to a non

- metered interme diary structure would pose a considerable challenge as it would be a departure from current business practices. If EPA’s intent in requesting this information is to assess the magnitude of hydrocarbon handled at a reporting facility, requiring facilities t o continue to report a facility “throughput” volume as opposed to a “sales” volume would provide a more accurate and realistic depiction of the volume of hydrocarbon handled at an intermediary facility that is not equipped with a custody transfer meter. Th erefore, we are proposing that EPA leave the facility throughput reporting language as it stands in the current rule for facilities located in OCS waters, and not implement the changes included in the proposed rule revision. Reporting a “throughput” as opp osed to a “sales volume” for a facility would also be consistent with the BOEM Gulfwide Offshore Activity Data Systems (GOADS) requirements, which requires OCS facilities to report throughput as part of the GOADS report. BOEM defines throughput as follows in the User’s Guide for the Gulfwide Offshore Activities Data Systems (GOADS): “Throughput

– total volume of natural gas or oil products handled at the current structure during the calendar year, including production volumes and volumes transferred via pip eline from another location.” Secondly, leaving the facility throughput reporting requirement language as it is in the current rule would also address the second issue we are presenting with the proposed change. EPA’s proposal requires sales volumes of oil and condensate to be reported separately. However, it is not uncommon for OCS facilities to blend all liquid products, including oil and condensate, together for custody transfer as a single liquid product stream. It would be difficult to efficiently and accurately separate the liquid custody transfer volumes between oil and condensate for those facilities where they are blended and transferred as a single product stream without conducting a well

- specific analysis of well test data across the hundreds of w ells feeding into a reporting facility. In addition, the definition of condensate included in 40 CFR 98.238 is not consistent with the commonly used industry language regarding condensate, which typically includes an API gravity cut off. Therefore, there i s room for interpretation among reporters as to what is considered condensate, which can lead to inconsistency in reporting across the offshore industry segment. Therefore, we recommend that EPA not alter the facility throughput reporting requirements for offshore facilities as is included in the March 10, 2014 proposal. If EPA does move forward with the proposed changes to the facility throughput reporting requirements, we request that EPA add clarifying language specifying that the volume of blended oil/c ondensate stream may be reported an oil stream, and that separation of blended oil/condensate streams for reporting purposes is not required. Response: The EPA disagrees that the information in §98.236(aa) (2) overreaches our authority to gather informatio n. The EPA has determined that these data elements §98.236(aa)(2) are useful and necessary for the verification of existing data and for characterizing the emissions from the industry segment. However, the EPA recognizes the commenter's concerns regarding the structure of offshore production facilities and the capability of a source to quantify sales volume versus throughput. We agree with that commenter that, because these operations typically operate as independent platforms and sales volumes may not be m etered until transfer

214to a pipeline, it is more appropriate to gather throughput information. Additionally, the EPA agree s with the commenter that it could be difficult to separate the liquid custody transfer volumes between oil and condensate. As such, we have revised the final reporting requirements to clarify that the quantit ies to be reported are throughput quantities (using wording from the BOEM definition) and that a single liquid quantity, which includes both oil and condensate. The final rule has be en revised to read as follows: "(2) For offshore production, report the quantities specified in paragraphs (aa)(2)(i) and (aa)(2)(ii) of this section. (i) The total quantity of gas handled at the offshore platform in the calendar year, in thousand standard cubic feet, including production volumes and volumes transferred via pipeline from another location.... (ii) The total quantity of oil and condensate handled at the offshore platform in the calendar year for sales, in barrels, including production volumes and volumes transferred via pipeline from another location."

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: (3) For na tural gas processing, report the quantities specified in paragraphs (aa)(3)(i) through (aa)(3)(vii) of this section. (i) The quantity of produced gas received at the gas processing plant in the calendar year, in thousand standard cubic feet. (ii) The quant ity of processed (residue) gas leaving the gas processing plant in the calendar year, in thousand standard cubic feet. (iii) The quantity of NGLs (bulk and fractionated) received at the gas processing plant in the calendar year, in barrels. (iv) The quanti ty of NGLs (bulk and fractionated) leaving the gas processing plant in the calendar year, in barrels. (v) Average mole fraction of CH4 in produced gas received. (vi) Average mole fraction of CO2 in produced gas received. (vii) Indicate whether the facility fractionates NGLs. Again, API does not understand the relationship between emission quantification and reporting and the data required to be reported in §98.236(aa)(3)(i) thru (iv). This appears to be another

215instance of using the GHGRP as a vehicle to co llect data EPA believes it may want that is not appropriate for an emission reporting program and overreaches EPA’s authority. Items §98.236(aa)(3)(i) thru (iv) should be stricken from the rule. Also, API would like to point out that items (i), (iii), and (iv) are not designated as CBI under Subpart W but are designated as CBI under Subpart NN of the GHGRP. Although the exact text differs slightly these are the same items with different CBI treatment under Subpart W and Subpart NN. API requests that they be similarly designated as CBI under Subpart W in conformance with their designation as CBI under Subpart NN. Response: The EPA disagrees that the information in §98.236(aa) (3) overreaches our authority to gather information. The EPA has determined that the se data elements §98.236(aa)(3) are useful and necessary for the verification of existing data and for characterizing the emissions from the industry segment

. Upon further review of the information proposed to be reported under § 98.236(aa)(3)(i), (iii), an d (iv), we have revised our CBI categorizations for these reporting elements. In the final rule, we have designated §98.236(aa)(3)(i) to be CBI and we have decided not to make a confidentiality determination for the elements in §98.236(aa)(3) (iii) and (iv ), See Section III.B of the preamble to the final rule for further discussion regarding the final CBI determinations

.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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Comment: In 40 CFR 98.236 (aa)(iii) and (iv), EPA requests natural gas processors to report the quantity of bulk and fractionated NGLs entering and leaving their processing plants. For GHG inventory purposes, Williams believes NGLs a re adequately tracked in Subpart NN for fractionation facilities receiving and supplying NGLs. Providing NGL information for natural gas processing plant under Subpart W, an emitter category, would be of little value to the national GHG inventory. Response : The data reported under subpart NN are the separate quantities of individual fractionated NGLs and bulk NGL received and supplied

. The data reported under subpart W are the aggregated quantities received and supplied of all individual fractionated NGLs and any bulk NGL. The EPA has determined that these aggregated values are useful and necessary for report verification and characterizing the emissions from the industry segment. See response to comment EPA

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- A3, Excerpt 20 of this section for a discussion of clarifications to the wording of these data elements in the final rule.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API)

216Document Control Number: EPA

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Comment: API has no objection to reporting of items §98.236(aa)(3)(v) through (vii) since they do not impose an undue burden on reporters. However, API would like to point out that where compositions are relevant to emissions fo r a particular source type, they are required to be reported in conjunction with that source type and reporting these items here is redundant and unnecessary. Response: The EPA has considered the commenter's concern and is retaining items §98.236(aa)(3)(v ) through (vii) in this final rule. Natural gas processing facilities may have many different configurations. For example, some facilities which only separate NGLs into component mixtures may not include acid gas removal vents or dehydrators. As such, not all facilities will be reporting the information provided in §98.236(aa)(3)(v) through (vii) with their calculated emission estimates. The provisions of §98.236(aa) capture these data for the entire industry segment reporting under Subpart W

.

Commenter N ame: Jeff Applekamp Commenter Affiliation: Gas Processors Association (GPA) Document Control Number: EPA

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Comment: EPA proposes several new reporting requirements related to gas throughput at a proces sing facility. EPA should replace the term "produced gas" with "natural gas". "Produced gas" is not a term that is defined and is not used in the midstream industry to refer to raw/inlet gas. Additionally, EPA has not provided a method for determining the natural gas and NGL throughputs it is requesting, and we therefore request that EPA retain the language that is in the current rule under 98.236(d) regarding "engineering estimate based on best available data." EPA proposes two new reporting requirements r elated to NGLs at processing plants, 98.236(aa)(3)(iii) and (iv). EPA requests "quantity of NGLs (bulk and fractionated)", which is vague. It’s unclear in both of these requirements if EPA is requesting one total volume or volumes separated into subgroups (such as y

- grade NGL, propane, E/P mix, etc). We propose that this be reworded to clearly indicate that only one number is requested per requirement. Otherwise, EPA needs to significantly revise this requirement to clarify which NGLs should be reported and how. For example, if a butane

- gasoline mix stream is a product of the processing plant, how would this stream be reported? 98.236(aa)(3) For natural gas processing, report the quantities specified in paragraphs (aa)(3)(i) through (aa)(3)(vii) of this sect ion , as determined by engineering estimate based on best available data

.

21798.236(aa)(3)(i) The quantity of produced natural gas received at the gas processing plant in the calendar year, in thousand standard cubic feet. 98.236(aa)(3)(ii) The quantity of processed (residue) gas leaving the gas processing plant in the calendar year, in thousand standard cubic feet. 98.236(aa)(3)(iii) The total quantity of all NGLs (bulk and fractionated , combined ) received at the gas proce ssing plant in the calendar year, in barrels. 98.236(aa)(3)(iv) The total quantity of all NGLs (bulk and fractionated , combined ) leaving the gas processing plant in the calendar year, in barrels. 98.236(aa)(3)(v) Average mole fraction of CH 4 in produced natural gas received. 98.236(aa)(3)(vi) Average mole fraction of CO 2 in produced natural gas received. Response: The EPA agrees with the commenter that the term "produced gas" may be confusing and has revised § 98.236(aa)(3) to refer to “natural gas

. ” Wh ile we understand that the commenter believes that the text “ as determined by engineering estimate based on best available data ” clarifies how the quantities of natural gas and NGL throughputs are determined , we note that the introductory text in §98.236(aa) already specifies that the information in paragraphs (a)(1) through (a)(9) are to be reported using “best available data”. Regarding § 98.236(aa)(3)(iii) and (iv), EPA is clarifying in the final rule that the “cumulative quantity of all NGLs (bu lk and fractionated)...” are to be reported. By referring to this as a cumulative quantity, we are clarifying that §98.236(aa)(3)(iii) is a single value representing the sum total of all NGLs (bulk and fractioned, combined) that are received at the gas proce ssing plant in the calendar year. Similarly, §98.236(aa)(3)(iii) is a single value representing the sum total of all NGLs (bulk and fractioned, combined) that are leaving the gas processing plant in the calendar year. The quantity of butane

- gasoline mix st ream produced by a gas processing plant would be added to the quantity of other products leaving the gas processing plant in order to determine the cumulative quantity of NGLs leaving the gas processing plant.



### 22.0 Confidentiality Determinations and Data Category Assignments for New or Revised Data Elements
22.1 E PA’s Approach to confidentiality determinations and data category assignments for new or revised data elements

Commenter Name: Karin Ritter Commenter Affiliation: American Pe troleum Institute (API) Document Control Number: EPA

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218Comment: EPA has committed to evaluate alternative approaches to calculation and reporting where disclosure of information is likely to cause substa ntial competitive harm. However, it has not followed its own process here. Response: The EPA undertook a complete review of all data elements as part of the development of the proposal, including reviewing all new and substantially revised data elements t hat are used as inputs to equations used to calculate the emissions. This review included assessing whether the data elements were already publicly available and for those data elements that are not already public, whether their disclosure posed a risk of causing substantial competitive harm to reporters. We note that many of the revisions to the calculation methods and reporting requirements are being made in response to specific recommendations made by industry. The proposal gave the industry an opportuni ty to comment on t he proposed changes to the calcu lation methods, identify reporting requirements that are sensitive, and suggest alternative calculation and reporting requirements that would avoid disclosure of any inputs to emission equations considered to be sens i tive. This approach is consistent with the approach we have taken with other rulemakings and allows for the appropriate level of review of confidentiali t y concerns by the EPA and industry.



### 22.2 Comments on proposed confidentiality determinations fo r data elements that are not inputs to emission equations

Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

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Comment: We support the Agency’s proposal to publicly disclose all new, existing, and substantially revised data reporting elements under Subpart W. 14 This action is required by the Clean Air Act’s provisions concerning disclosure of data collected under the Reporting Rule and is critica l to ensure transparency and promote accountability. 15 Moreover, public disclosure will help promote efforts to refine other emissions estimation programs such as the Annual Inventory of U.S. Greenhouse Gas Emissions and Sinks. EPA’s determinations are in accord with past determinations on similar types of data.
Footnotes:

14 Id. at 13,405

– 20. 15 Section 114(c) of the Clean Air Act requires EPA to disclose “emission data” regardless of whether that data would otherwise be considered confidential business in formation. 42 U.S.C. § 7414(c). Moreover, long

- standing EPA regulations have interpreted “emission data” broadly to include “[i]nformation necessary to determine the identity, amount, frequency, concentration, or other characteristics . . . of any emission which has been emitted,” or information necessary to determine the characteristics of any emissions which “under an applicable standard or limitation” a source may emit, or even “[a] general description of the location and/or nature of the source.”

21940 C.F .R. § 2.301(a)(2)(i). EPA is under a duty to disclose data that is publically available and not commercially sensitive. See Envtl. Def. Fund et al., Comments Regarding Proposed Deferral of Greenhouse Gas Reporting and Call for Information (Docket ID Nos. E PA

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- 0964) (Mar. 7, 2011). Response: The EPA thanks the commenter for their support. With consideration of the data provided by commenters on the proposed rule, the EPA is finalizing the confidentiality determinations as pro posed for all but 7 of the new and substantially revised data elements that were proposed. See Section III .B of the preamble to the final rule for additional information related to confidentiality determinations

.

Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

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Comment: The Agency has conducted specific analyses and made individual determinations on 11 data elements, recognizing that “simila r data elements may not always have the same confidentiality status.” 16 On this basis, EPA correctly concluded that these 11 data elements are not confidential business information because the information being reported is already publicly available.

16 79 Fed. Reg. at 13,406. The 11 data elements can be found in Table 3 of the proposed rule. Id. at 13,419. Response: The EPA thanks the commenter for their support. With consideration of the data provided by commenters on the proposed rule, the EPA is finalizing the confidentiality determinations as proposed for all but 4 of the new and substantially revised data elements in Table 3 of the preamble to the proposed rule. See responses to comments EPA

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- A2, Excerpts 139, 140, 14 1, and 142 and Section III of the preamble to the final rule for additional information about the decisions to change the confidentiality determinations for the 4 data elements

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Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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Comment: Kinder Morgan supports classifying proposed § 98.236(d)(1)(iv) (Whether any CO 2 emissions from the acid gas removal unit are recovered and transferr ed outside the facility)) as CBI. The Agency has not made a prior CBI determination on this specific data element, and is proposing to classify it as "Not CBI." However, this specific data element is directly linked to

220multiple data elements associated wit h industrial CO 2 production plants and importers/exporters of CO2 that have been previously determined to be CBI under 40 CFR 98, Subpart PP. 5
FOOTNOTE:

5 These multiple data elements generally fall in the category of annual CO 2 mass in metric tons supplie d or exported to a container or downstream location. Since the reporting of this item under Subpart W effectively requires the reporter to also report the annual quantity of CO 2 in metric tons that was recovered and transferred outside the facility, this i tem should also receive the same CBI treatment that was established under Subpart PP for the reporting of the annual quantity of CO 2 in metric tons. See Confidentiality Determinations for Data Required Under the Mandatory Greenhouse Gas Reporting Rule and Amendments to Special Rules Governing Certain Information Obtained Under the Clean Air Act , Final Rule , 76 FR 30782 (May 26, 2011). Response: The final amendments revise §98.236(d)(1)(iv) to be consistent with §98.236(c)(3)(iv) of the current rule. Specifically, the final amendments state that the quantity of CO 2 emissions from acid gas removal units that are recovered and transferred offsite must be reported under subpart PP; the proposed amendments inadvertently removed the requirement to report un der subpart PP. See Section III.B of the preamble to the final rule for a discussion of the EPA’s determination that the requirement to indicate whether CO 2 emissions are recovered from acid gas removal units and transferred offsite is not CBI.

Commenter Name: Glen Jasek Commenter Affiliation: Williams Partners, LP Document Control Number: EPA

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Comment: Proposed EPA Amendment: Among other additional data elements being requested for centrifugal and reciprocating compressors in 40 CFR 98.236 (o) and (p), EPA is seeking the following information:

• Compressor power rating (hp);

• Year compressor was installed;

• Compressor model name and description;

• Date of last maintenance shutdown that compressor was depr essurized. We view this data to be confidential business information (CBI). Response: As discussed in the response to comment EPA

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- A2, Excerpt 2 of section 21 of this document and Section II.E.2 of the preamble to the final rule, the EPA has made several changes to the compressor data elements for the final rule. First, we removed the installation year and compressor model name and description data elements from

221the final rule. Second, the compressor power rating has been replaced with a requirement to report the “ power output of the compressor drive r .” Third, we replaced the reporting requirement for the date of the last maintenance shutdown with a simple indication of whether the compressor had a scheduled depressurized shutdown duri ng the reporting year. The EPA has determined that the power output of the compressor drive r should not be CBI because such information is generally publicly available in operating and construction permits and in FERC documents. An indication of whether a scheduled depressurized shutdown of the compressor occurred during the reporting year is not already public; however, it provides no insight into the length of the shutdown, the reason for the shutdown, or the timing of future shutdown events. It also pro vides no information on emergency shutdowns for malfunctions. Furthermore, facilities frequently have backup compressors so that there will be no service disruption during maintenance and repair periods. The commenter did not explain why these specific dat a elements were considered sensitive, nor explain how they could be used by competitors to harm their company. Since we know of no reasons why these data elements would cause competitive harm, the EPA is finalizing the determinations that the two revised d ata elements are not CBI.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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Comment: Confidentiality: EPA fa ils to understand the competitive nature of the natural gas transmission industry when determining whether particular data elements should be considered confidential business information (CBI). EPA’s decision to not designate T&S data as CBI is based, at least in part, on its understanding that the transmission industry is inherently less competitive than other industries. EPA’s understanding is indicated in text from the preamble that explains the CBI determination for many transmission data elements: "Companies operating in this (natural gas transmission compression sector) sector are subject to regulatory oversight by the Federal Energy Regulatory Commission (FERC), state utility commissions, and other federal agencies because they operate in an indus try that is inherently uncompetitive. FERC controls pricing, sets rules for business practices, has the power to impose conditions on mergers and acquisitions, and has the sole responsibility for authorizing the location, construction and operations of com panies operating in this sector. The rate charged for transporting gas is regulated. Hence the tightly regulated natural gas transmission sector is inherently less competitive than other industries." EPA’s understanding that the natural gas transmission in dustry is inherently less competitive than other industries is not correct. While interstate natural gas pipeline rates are established on a cost

- of

- service basis by the Federal Energy Regulatory Commission (FERC), the natural gas pipeline transportation m arket is quite competitive. In the mid 1980s, FERC began a major

222restructuring of pipeline companies’ services, with the ultimate goal of enabling consumers to purchase gas directly from producers in a competitive market for natural gas. Since the mid 1990 s, when FERC issued Order 636, the unbundling of pipelines’ merchant and transportation services has been mandatory. The competitive culture fostered by Order 636 has replaced the public utility culture of the pre

- restructuring natural gas industry. Pipeli nes face multiple forms of competition which affect service offerings and prices, including: competition with alternative fuels, competition between gas supply basins, competition among pipelines, and increased competition with firm shippers who can sell t heir excess capacity on a secondary market. Given the competitive alternatives that customers enjoy, a pipeline’s FERC

- approved maximum tariff rate is not an entitlement to collect such a rate. Rather, a pipeline’s pricing power is disciplined by what the market will bear. As a result, a significant portion of interstate pipeline throughput is being transported at rates that have been discounted from the FERC

- approved maximum tariff rates or under agreements where the pipeline and its customer have negotiat ed an alternative rate design and rate level. As a result, small changes in the delivered price of natural gas can affect competitiveness so it is imperative for pipelines to manage costs because there is no guarantee of cost recovery. If a pipeline’s cost s become too high, a customer could take its business to a competitor once its contract expires. The natural gas pipeline market is indeed competitive and INGAA urges EPA to recognize this. EPA refers to public information available for natural gas compani es subject to the jurisdiction of FERC because FERC Forms 2, 2

- A, and 3

- Q must be submitted. These reports are designed to collect financial and operational information, and are considered to be non

- confidential public use forms. However, these forms do no t contain all of the equipment, process, and operating data regarding industry operations and practices, and do not include all proposed Subpart W data elements. Thus, the confidentiality determinations for these data elements should consider whether discl osure of the data is likely to cause substantial harm to a natural gas transmission company’s competitive position. Response: For the reasons discussed in Section III.B of the preamble to the final rule , the EPA has decided to change the confidentiality d eterminations for the data elements in §98.236(aa)(4)(i), (iv) and (v) due to concerns that these data elements provide information on the quantity of gas transported by a specific pipeline and these data may potentially cause competitive harm to some pipe line companies operating in more competitive market areas.

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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Comment: Contr ary to EPA’s perception, the natural gas industry is a very competitive industry. Each company competes with other companies to attract shipper commitments to provide natural gas transportation, processing and storage services to meet producer, industrial and residential customer needs and demands.

223Kinder Morgan and other natural gas pipeline companies compete against one another and cannot automatically pass on regulatory costs to their customers. Even though Kinder Morgan operates pipelines subject to reg ulatory oversight by the Federal Energy Regulatory Commission (FERC) and other federal and state agencies, Kinder Morgan operates in markets in which other natural gas pipeline companies regularly compete for pipeline business through discounting and other competitive market practices. Rate proceedings to establish shipping rates for an interstate natural gas pipeline do not occur annually, and typically occur only once every several years. Thus, new costs incurred between rate cases

– such as increased reg ulatory costs caused by new regulation

– cannot be automatically added to the shipping rate and are instead born by the pipeline company. Any contention that Kinder Morgan and other interstate natural gas pipeline companies "operate in an industry that is inherently uncompetitive" is mistaken. 2 EPA’s failure to designate natural gas industry data as CBI is based in part on the faulty assumption that the natural gas transmission industry is "inherently uncompetitive" or "inherently less competitive than other industries." 3 As noted above, the natural gas industry is very competitive. The release of specific compressor throughput, gas storage injection and withdrawal, LNG import and export volume and other specific operational data could provide competitor s and gas marketers with market sensitive information that could result in substantial harm to a pipeline operator’s competitive position.
FOOTNOTE:

2 See , e.g. , Proposed Rule at 13411. 3 See id

. Response: See the response to comment EPA

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Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Docume nt Control Number: EPA

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- A1 Comment Excerpt Number: 2
Comment: As noted in detail in API and INGAA’s comments, EPA’s proposed confidentiality determinations conflict with determinations made in prior versions of Subpart W as well as in other subparts of Part 98. In several instances, EPA is changing classifications for data that it previously deemed CBI without justifying its decision to reclassify the data. Examples include the proposed confidentiality determinations for annual quant ities of gas transported through a compressor station (proposed § 98.236(aa)(4)(i)); gas injected into and withdrawn from underground natural gas storage (proposed § 98.236(aa)(5)(i) and (ii)); and LNG imported or exported (proposed § 98.236(aa)(6) and (7) ). For each of these proposed confidentiality determinations, Kinder Morgan supports INGAA’s comments calling for the classification of such data as CBI, and notes that EPA had already made a CBI determination that encompasses the data element in the curre nt § 98.236(d). 4

224Footnotes:

4 "Memorandum

- Final Data Category Assignments and Confidentiality Determinations for the 2012 Final CBI Rule," Lisa Bacanskas, EPA, Climate Change Division, Docket ID No. EPA

HQ

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- 0031 (Aug. 1, 2012), Table 1 at 14. Response: In the proposal, we indicated that the existing reporting section had been reorganized and some of the reporting requirements were removed from the rule. The requirement in §98.236(d) of the current rule to report throughput for each industry se gment is one of the data elements removed from the rule. This data element has been replaced by new reporting requirements that are specific to each industry segment

. During the development of the proposal, the EPA evaluated each of the new data elements , proposed determinations based on this new evaluation, and sought comment on our proposed determinations . The EPA now is making final determinations taking into consideration all stakeholder comments. As discussed in detail in Section III.B of the preamble, the EPA has reviewed the subpart W determinations with those made for other subpart s and identified two subpart NN data elements with CBI determinations that are inconsistent with those proposed for subpart W. Those data elements are the quantity of gas r eceived at a gas processing plant (reported under § 98.236(aa)(3)(i)) and the quantity of natural gas withdrawn from storage (reported under §98.236(aa) (5)(i) )

. R eview of publicly available data undertaken during the preparation of the proposal for this act ion found that the quantity of natural gas withdrawn from storage is publicly available through the EIA website and is therefore not entitled to confidential treatment under 40 CFR 2.208

. As a result, we are finalizing the proposed determination that the q uantity of natural gas withdrawn from storage and reported under § 98.236(aa)(5)(i) is not CBI. The quantity of gas received at gas plants also is publicly available from EIA. However, the data are available only every third year. Thus, for reasons discusse d in Section III.B of the preamble to the final rule, we are changing the determination for §98.236(aa)(3)(i) from “not CBI” to “CBI.” The gas withdrawn from underground natural gas storage (proposed §98.236(aa)(5)(ii)) is publicly available from EIA, and the monthly quantities of LNG imported or exported (proposed §98.236(aa)(6) and (7)) are publicly available in quarterly reports issued by the Office of Fossil Energy in the Department of Energy. Thus, these data elements are not entitled to confidential treatment under 40 CFR 2.208

. See response to comment EPA

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- A1, Excerpts 37 and 67 of this section and Section III.B of the preamble to the final rule for a discussion of the EPA’s revised determination for §98.236(aa)(4)(i).

Commente r Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 38

225Comment: EPA should more thoroughly review the CBI status of T&S data eleme nts. Several data elements should be considered CBI. The Proposed Rule does not designate any data elements for the T&S segments as CBI. This is due, in part, to EPA’s mistaken belief that the T&S segments are not competitive. Because of this faulty logic , T&S data CBI determinations discussed in the preamble should be revisited. INGAA recommends that EPA consider classifying several data elements as CBI. In some cases, EPA has already required reporting, but a non

- CBI determination was not documented. The following data elements are all stand

- alone parameters that are not required in any equations or methods for estimating GHG emissions, and their purpose is not defined. In each case, the parameter divulges important information on production, operations, or key process equipment. INGAA recommends EPA re

- evaluate its classification as CBI based on a thorough review following defined procedures and based on a competitive business environment for T&S data elements, including:

• Annual quantity of gas transporte d through the transmission compressor station, §98.236(aa)(4)(i);

• Annual quantity of gas injected and withdrawn into underground natural gas storage, §98.236(aa)(5)(i) and (ii);

• Annual quantity of LNG imported and exported for LNG import and export equipme nt, §98.236(aa)(6) and (7);

• Several parameters that have been added to reporting requirements are discussed in Comment 17, including compressor power rating (hp), year the compressor was installed, compressor model name and description, and date of last ma intenance. These parameters should also be considered for classification as CBI, especially maintenance related data elements. Response: See response to comment EPA

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- A1, Excerpts 37 and 67 in this section for information regarding §98 .236(aa)(4)(i). See response to comment EPA

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- A1, Excerpt 2 of this section and Section III.B of the preamble to the final rule for information regarding data elements in §98.236(aa)(5)(i), (5)(ii), (6), and (7).
See response to comment EPA

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- A2, Excerpt 16 of this section for the response to the comment regarding compressor data elements.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 139
Comment: Proposed Citation Reference: §98.236(aa)(3) and (aa)(3)(i), Proposed Rule Text: (3) For natural gas processing, report the quantities specified in paragraphs (aa)(3)(i) through

226(aa)(3)(vii) of t his section. (i) The quantity of produced gas received at the gas processing plant in the calendar year, in thousand standard cubic feet.
Comment: EPA determined this data to be CBI under 40 CFR 98 Subpart NN (98.406(a)(3)) per 76 FR 30782, 5/26/2011 (Annu al volumes of natural gas received for processing). Even though the terminology is slightly different between Subpart W and Subpart NN, the “quantity of produced gas received at the gas processing plant” vs. “annual volumes of natural gas received for proc essing” are essentially the same data so it should likewise be treated as CBI under Subpart W as it was determined under Subpart NN. Response: For the reasons discussed in the response to comment EPA

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- A1, Excerpt 2 of this section and Section III.B of the preamble to the final rule , the EPA is changing the determination for §98.236(aa)(3)(i) from “not CBI” to “ CBI.”

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 141
Comment: Proposed Citation Reference: §98.236(aa)(3)(iii), Proposed Rule Text: The quantity of NGLs (bulk and fractionated) received at the gas processing plant in the calendar year, in barrels
EPA det ermined this data to be CBI under 40 CFR 98 Subpart NN (98.406(a)(4) and (a)(4)(i)) per 76 FR 30782, 5/26/2011 and 78 FR 71904, 11/29/2013 (Annual Quantity (in barrels) of y

grade, o

- grade, and other bulk NGLs received). Even though the terminology and the type of NGLs being aggregated is slightly different between Subpart NN and Subpart W, it is still considered NGLs received at the facility so it should still be retained as CBI under Subpart W as it was determined under Subpart NN. Response: For the reasons discussed in Section III.B of the preamble to the final rule , the EPA has decided not to make a confidentiality determination for §98.236(aa)(3)(iii)

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API ) Document Control Number: EPA

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- A2 Comment Excerpt Number: 142
Comment: Proposed Citation Reference: §98.236(aa)(3)(iv), Proposed Rule Text: The quantity of NGLs (bulk and fractionated) leaving the gas processing plant in the report ing year (barrels). EPA determined this data to be CBI under 40 CFR 98 Subpart NN (98.406(a)(4)(ii)) per 78 FR 71904, 11/29/2013 (Annual Quantity (in barrels) of y

- grade, o

- grade, and other bulk NGLs

227supplied to downstream users that are not fractionated b y the reporter). Even though the terminology and the type of NGLs being aggregated is slightly different between Subpart NN and Subpart W, it is still considered NGLs generated at the facility so it should still be retained as CBI under Subpart W as it was determined under Subpart NN. Response: For the reasons discussed in Section III.B of the preamble to the final rule , the EPA has decided not to make a confidentiality determination for §98.236(aa)(3)(iv)

.

Commenter Name: Jeff Applekamp Commenter Affil iation: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number: 1
Comment: 1. Quantity of produced gas received at the gas processing plant: Section 98.236(aa)(3)(i) requires affected sources to r eport the quantity of produced gas received at the gas processing plant in the calendar year. EPA proposes that this information should not be CBI. Yet, EPA determined this data to be CBI under Subpart NN (98.406(a)(3)). Even though the terminology is slig htly different between Subpart W and Subpart NN, the "quantity of produced gas received at the gas processing plant" and "annual volumes ... of natural gas received for processing" are essentially the same data. Therefore, this data should be considered CBI under Subpart W, as it is under Subpart NN. 2. Quantity of NGLs (bulk and fractionated) received at the gas processing plant: Section 98.236(aa)(3)(iii) requires affected sources to report the quantity of NGLs (bulk and fractionated) received at the gas pr ocessing plant in the calendar year. EPA proposes that this information should not be CBI. Yet, EPA determined these data to be CBI under Subpart NN (98.406(1)(2), (a)(4) and (a)(4)(i)). Even though the terminology and the type of NGLs being aggregated are slightly different between Subpart NN and Subpart W, both constitute NGLs received at the facility. This information should be retained as CBI under Subpart W, as it is under Subpart NN. 3. Quantity of NGLs (bulk and fractionated) leaving the gas processing plant: Section 98.236(aa)(3)(iv) requires affected sources to report the quantity of NGLs (bulk and fractionated) leaving the gas processing plant in the calendar year. EPA proposes that this information should not be CBI. Yet, EPA determined th ese data to be CBI under Subpart NN (98.406(a)(1), (a)(4), and (a)(4)(ii)). Even though the terminology and the type of NGLs being aggregated are slightly different between Subpart NN and Subpart W, both constitute NGLs leaving the facility. This informati on should be retained as CBI under Subpart W, as it is under Subpart NN. Response: See response to comment EPA

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- A1, Excerpt 2 of this section; response s to comments EPA

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- A2, Excerpts 139, 1 41, and 142 of this sect ion; and Section III.B of the preamble to the final rule for the EPA’s response to this comment.

228Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excer pt Number: 140
Comment: Proposed Citation Reference:§98.236(aa)(3)(ii), Proposed Rule Text: The quantity of processed (residue) gas leaving the gas processing plant in the calendar year, in thousand standard cubic feet. Although the EPA did not make a prior CBI determination for this data element under Subpart NN there is no explanation why this data element needs to be reported under Subpart W and why it is designated as not

- CBI. Response: The data element identified by the reporter will be used for v erification of annual reports. For reasons discussed in section III.B of the preamble to the final rule, the EPA is changing the confidentiality determination for § 98.236(aa)(3)( i i) from “not CBI” to “CBI”.

Commenter Name: Jeff Applekamp Commenter Affi liation: Gas Processors Association (GPA) Document Control Number: EPA

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- A3 Comment Excerpt Number: 2
Comment: Quantity of processed (residue) gas leaving the gas processing plant: Section 98.236(aa)(3)(ii) requires affected sources to report the quantity of processed (residue) gas leaving the gas processing plant in the calendar year. There is no explanation for why this data element needs to be reported under Subpart W and minimal explanation as to why it is designated as non

- CBI. In Table 3 of the proposed rule, EPA claims that this data is "published quarterly on EIA’s Website." But it appears that plant

- specific processing capacity information is supplied to EIA via Form EIA

- 757, which, according to the General Instructions on th e form, is "collected from all processing plants at most once every 3 years." For lack of justification to treat this data as non

- CBI, it should be retained as CBI. Response: S ee the response to the comment EPA

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- A2, excerpt 140 in th is section for the response to the comment regarding reporting the quantity of residue gas leaving the natural gas plant ( § 98.236 (aa) (3)(ii)).

Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Nu mber: EPA

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Comment: Kinder Morgan also supports API’s comments requesting that the following proposed new data elements under Subpart W be classified as CBI to be consistent with prior

229CBI determinations made under Subpart NN: the annual quantities of produced gas received at the gas processing plant (proposed § 98.236(aa)(3)(i)(A)); processed (residue) gas leaving the gas processing plant (proposed § 98.236(aa)(3)(ii)); NGLs (bulk and fractionated) recei ved at the gas processing plant (proposed § 98.236(aa)(3)(iii)); and NGLs (bulk and fractionated) leaving the gas processing plant (proposed § 98.236(aa)(3)(iv)). Response: See the responses to comments EPA

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Commenter Name: Karin Ritter Commenter Affiliation: Americ an Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 16
Comment: Conformance of Confidentiality Determinations amongst GHGRP Subparts. API has identified several data reporting elements in §98.236(aa )(3)(i) through (aa)(3)(vii) that are proposed as ‘not

- CBI’ under Subpart W at the same time that they have been designated as ‘CBI’ under Subpart NN of the GHGRP. Details regarding these data items are provided below in the technical comments. API expects that EPA will afford the same CBI protections to specific data elements in all Subpart s of the GHGRP. We request EPA conduct a conformity review to ensure that data elements receive the same CBI designation in various parts of the GHGRP. Response: See th e responses to comments EPA

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.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 30
Comment: Conformance of Confidentiality Determinations amongst GHGR P Subparts. As discussed above, API has identified several data reporting elements in §98.236 (aa)(3)(i) through (aa)(3)(vii) that are proposed as “not

- CBI” under Subpart W while at the same time they have been designated as “CBI” under Subpart NN of the G HGRP. Details regarding these data items are provided below in the technical comments. In order to avoid arbitrary and capricious treatment of information, EPA must afford the same CBI protections to specific data elements in all Subparts of the GHGRP. Mor eover, EPA should conduct a conformity review to ensure that data elements are designated CBI in a consistent manner in various parts of the GHGRP.

230Response: See the responses to comments EPA

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Commenter Name: Thomas J. Bach Commenter Affiliation: Kinder Morgan Energy Partners, L.P Document Control Number: EPA

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- A1 Comment Excerpt Number: 4
Comment: Kinder Morgan also supports the CBI conformity request proposed by API to establish consistency in CBI determinations across all Subparts of the Greenhouse Gas Reporting Program (GHGRP). Response: See the responses to comments EPA

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.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 135
Comm ent: Proposed Citation Reference: §98.236(aa)(2) and (aa)(2)(i), Proposed Rule Text:(2) For offshore production, report the quantities specified in paragraphs (aa)(2)(i) through (aa)(2)(iii) of this section. (i) The quantity of gas produced from the offsh ore platform in the calendar year for sales, in thousand standard cubic feet.
Comment: This is a CBI concern

. This information is typically not disclosed for individual platforms. Response: For the reasons discussed in the response to comment EPA

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- A2, Excerpt 90 in Section 21.0 of this document, the EPA is revising the proposed requirement to report the quantity of gas produced with a requirement to report the quantity of gas handled at the offshore platform. The finalized data element is consistent with BOEM reporting requirements. This quantity is also publicly available from BOEM, which means it is not entitled to confidential treatment under 40 CFR 2.208. Thus, as part of this action we are finalizing our determination that the revi sed data element in §98.236(aa)(2)(i) is not CBI.

231Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 136
Comment: Proposed Citation Ref erence: §98.236(aa)(2)(ii), Proposed Rule Text: The quantity of oil produced from the offshore platform in the calendar year for sales, in barrels This is a CBI concern. This information is typically not disclosed for individual platforms. Response: For the reasons discussed in the response to comment EPA

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- A2, Excerpt 90 in Section 2 1 .0 of this document , the EPA is replacing the proposed requirements to report the amount of oil produced (proposed §98.236(aa)(2)(ii)) and the amount of condensate produced (proposed §98.236(aa)(2)(iii)) with a single requirement to report the combined total quantity of oil and condensate handled at the offshore platform (final §98.236(aa)(2)(ii)). The finalized data element is consistent with BOEM reporti ng requirements. This quantity is also publicly available from BOEM, which means it is not entitled to confidential treatment under 40 CFR 2.208. Thus, as part of this action we are finalizing our determination that the data element in §98.236(aa)(2)(ii) i s not CBI

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 138
Comment: Proposed Citation Reference: §98.236(aa)(2)(iii), Proposed R ule Text: The quantity of condensate produced from the offshore platform in the calendar year for sales, in barrels.
T his is a CBI concern. This information is typically not disclosed for individual platforms Response: For the reasons discussed in the res ponse to comment EPA

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- A2, Excerpt 90 in Section 2 1 .0 of this document , the EPA is replacing the proposed requirements to report the amount of oil produced (proposed §98.236(aa)(2)(ii)) and the amount of condensate produced (proposed §9 8.236(aa)(2)(iii)) with a single requirement to report the combined total quantity of oil and condensate handled at the offshore platform (final §98.236(aa)(2)(ii)). The finalized data element is consistent with BOEM reporting requirements. This quantity i s also publicly available from BOEM, which means it is not entitled to confidential treatment under 40 CFR 2.208. Thus, as part of this action we are finalizing our determination that the data element in §98.236(aa)(2)(ii) is not CBI

.

232

### 22.3 Comments on evaluation of inputs to emissions equations for new or revised data elements

Commenter Name: V. Bruce Thompson Commenter Affiliation: American Exploration & Production Council (AXPC) Document Control Number: EPA

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Comment: AXPC and the Alliance understand that many of the data inputs that were previously not reported due to confidential business considerations will now have to be reported for previous and current reporting years. However, as noted above, the transition to a new and unknown reporting format, along with the additional data gathering and management modifications will take time to implement. As proposed, as soon as these changes are made and implemented, reporters would have to make additiona l modification for reporting year 2015 forward. This short timeframe is unreasonable, particularly considering that the rule is expected to be finalized near the end of 2014 and reporters would need to have data gathering systems and processes in place sta rting at the first of the year, 2015. As such, we request that EPA allow for additional implementation time and believe that it is reasonable for operators to report 2011

‐ 2015 inputs in 2016 and 2016 inputs and modified emission calculations in 2017. Respo nse: We disagree with the commenter's request to delay reporting of data elements that are inputs to emission calculation equations and have been deferred from reporting in reporting years 2011 through 2013. As discussed in the preamble to a separate rule making action (insert citation to final inputs rule FR notice) we recognize that a substantial number of inputs must be back

- reported for these years. To facilitate this process, the EPA has develop ed a reporting form that will be used to collect the back

- reported i nputs data and a reporting form for the 2014 reporting year

. Both forms have been made available for stakeholder review

. This allow s facilities to become familiar with the data entry prior to the March 2015 reporting deadline

. In light of th is , we have determined that the re is sufficient time to complete both back

- reporting inputs data for previous reports and the reports for reporting year 2014. The EPA also notes that in the final rule, we are providing a transitional BAMM period for emission s ources that are subject to new monitoring or measurement requirements as part of these final revisions . See Section II.D of the preamble to the final rule for addition al discussion regarding BAMM

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Potential Antitrust Concerns. As API has made clear to EPA in earlier comments

– including the November 2013 comments submitted to EPA that are attached and incorporated herein by reference

– if EPA fails to take sufficient action to protect public disclosure of confidential inputs data outside the proper definition of “emission data,” significant antitrust concerns may arise. As t he Federal Trade Commission (FTC) has made clear to EPA, failing to

233protect confidential “inputs to emissions equations” data elements from disclosure could trigger antitrust concerns and violate the principle of aggregation. EPA must avoid imposing a requ irement to disclose data beyond that which is properly classified as “emission data” because such disclosure is inconsistent with statutory requirements and policies promoting competition.
The data elements of concern include cost

- and output

- related infor mation that is a significant determinant of prices including information regarding fuel production and distribution (which provides details about inputs, nature and location of sources, and plant operations). The antitrust laws generally prohibit competito rs from sharing price, output, and other information that may facilitate anticompetitive coordination in prices or production and thereby harm consumers. The exchange of price information is of particular concern. 7 See United States v. Container Corp. of A merica, 393 U.S. 333 (1969); see also Federal Trade Commission (FTC) FTC Guide to the Antitrust Laws http://www.ftc.gov/bc/antitrust/factsheets/antitrustlawsguide.pdf

. Becaus e the Antitrust laws prohibit agreements to restrict output, see United States v. Andreas, 216 F.3d 645, 666

- 69 (7th Cir. 2000), a similar set of antitrust concerns apply to information

- sharing (tacit or explicit) that may facilitate coordinated output decisions. Thus, any public disclosure of confidential and sensitive business information beyond strictly “emission data” would violate well

- settled principles that shared data should be “sufficiently aggregated” and should “not allow recipients to identif y” the competitive information of “any particular provider.” Without such safeguards, producers are more likely to learn the specifics of individual competitors’ ongoing operations. Such knowledge could impact prices and/or output and the risk of causing c ompetitive harm increases because some sensitive aspects of fuel production may persist over time. EPA’s proposed rule fails to address these concerns. As discussed above, EPA must confirm that any elements it deems confidential are not “emission data.” Ot herwise, such data elements might be available for disclosure to the public.8 As the FTC has explained, because numerous industries subject to the GHGRP share various market conditions, “making confidential business information (CBI) public may lead to col lusion that harms consumers through higher prices, decreased quality, and decreased innovation.” Comments of the Federal Trade Commission, September 30, 2010 at 2. More specifically, the FTC expressly highlighted its concerns about EPA’s proposed release o f “inputs to emission equations” and other sensitive data elements explaining that: "Three categories of data that the EPA proposes to make public contain potentially sensitive competitive business information: “inputs to emission equations,” “unit process ‘static’ characteristics that are not inputs to emission equations,” and “unit/process operating characteristics that are not inputs to emission equations.” These three categories include data on production, throughput, raw material consumption, capacity, and future operations. Public disclosure of such facility

- and firm

- specific sensitive business information may make it easier for reporting companies to either tacitly or explicitly coordinate their pricing decisions. This is especially true when certain market conditions are present such as transparency, high concentration, impediments to entry, homogenous products, and low elasticity of demand. See Comments of the FTC (emphasis added; internal footnotes omitted).

234As a result of its concerns, the FTC rec ommended that EPA treat all “inputs to emission equations” data elements as confidential. Id. Because the FTC is the federal agency specifically charged with maintaining competition and safeguarding the interests of consumers, we urge EPA to be particularl y deferential of its advice regarding the serious need to take adequate steps to avoid disclosing sensitive data. API continues to urge EPA to follow the FTC’s recommendations and provide CBI protection to: (1) all “inputs to emission equations” particular ly where there is not a sufficient record upon which to determine how EPA excluded some inputs as confidential; and (2) information regarding exploratory wells which must be protected from disclosure (which is discussed further below in D.4 and D.5).
Foot note s :

7 The antitrust laws are designed to promote and preserve the competitive private enterprise system by encouraging free and open competition and the fairest distribution of high quality goods and services at the lowest possible prices. The basic pr ovisions of the antitrust laws are found in the Sherman Act, Clayton Act, Robinson

- Patman Act, and the Federal Trade Commission Act. Distilled, these Acts oblige regulated entities to ensure that they do not discuss or exchange information with their compe titors on issues such as prices to be charged, division or allocation of markets or customers, distribution of products, profit levels, production of products or level of production, bases for determining prices, and exchanges of price information to certa in customers, among other issues. Violations of these Acts can lead to imprisonment, fines, court

- issued injunctions, treble damage awards, and state penalties. As noted supra , the FTC submitted comments in EPA’s CBI rulemaking and took the position that E PA’s proposed rule “may allow for the public release of competitively sensitive information” and, in particular, pointed to data under three categories that were at high risk and warranted confidential protection: “inputs to emission equations,” “unit/proc ess ‘static’ characteristics that are not inputs to emission equations,” and “unit/process operating characteristics that are not inputs to emission equations.” See FTC Comments at 6. With respect to “inputs to emission equations,” the FTC pointed out that “inputs to emission equations” include annual fuel combustion volume, production/throughput and raw material consumption (such as petrochemical production), characteristics of raw materials, products, and by

- products, and facility operating information wh ich, if not characterized as “emission data,” would otherwise be CBI.

8 In API’s September 7, 2010 comments, API members expressed concern that some of the Suppliers’ reporting requirements could reveal process

- specific information and production volumes, thus providing competitors with data about sensitive process capabilities and operational limits and market capabilities and engagements. For these reasons, API has previously stated that petroleum fuel refiners, importers, and exporters should not have to report on petroleum feed stock and product volumes or unit

- specific GHG emissions and process data to EPA unless assured the confidentiality of these data. Response: Section 114(c) of the Clean Air Act requires EPA to make information publicly available unless it is CBI. It precludes “emission data” from being protected as CBI. Therefore, “emission data” must be publicly available even if they are CBI

. In this rulemaking, EPA categorized several data elements as “emission data” based on the definition of the term at 40 CFR 2.301(a)(2)(i). EPA carefully construed the regulatory definition to include only those data elements necessary to determine the emission information specified in 40 CFR 2.301(a)(2)(i)(A)

235or to distinguish one source of emissions from an other as required in 40 CFR 2.301(a)(2)(i)(C)

. For data elements that were used to calculate emissions, we evaluated whether those data elements could cause potential harm to reporters if they were reported and disclosed

. For data elements that do not mee t the definition of emissions data, we proposed confidentiality determinations based on an evaluation of the criteria from the existing CBI regulations at 40 CFR 2.208. The criteria do not require EPA to assess potential violation or enforcement under anti trust law. However, based on 40 CFR 2.208(e)(1), EPA evaluated whether disclosure of data elements that are not emission data would be likely to cause competitive harm to the reporter. We also solicited comment on our proposed determinations and on our har m analysis for data elements used as inputs to emission calculations. We made final determinations after careful evaluation of the comments we received.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Con trol Number: EPA

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Comment: API once again reasserts previous legal and technical comments regarding CBI, which API submitted to EPA on November 29, 2013. Thus, API incorporates the November 29, 2013 com ments (including legal objections to EPA’s treatment of CBI) by reference hereto and also attaches such comments to this comment package. Response: See the response to comment EPA

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### 22.4 Concerns related to exploratory wells

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Federal law 1 and state codes 2 specifically allow compan ies to designate as confidential , data obtained from exploratory wells, particularly wells in new discovery areas, or areas that are being explored for development. The original intent of state oil and gas commissions and federal officials to allow withhol ding of select drilling and production information from early release to the public was to promote competitive exploration by searching for new pockets of oil or gas and experimenting with new tools and techniques. Requiring release of data to the public r egarding operating characteristics of such wells, including post

- flowback flaring/venting volumes, could cause competitive harm if made publicly available too early. Industry makes substantial investments in exploration and development projects in new area s. These investments in exploration take a long time to characterize the magnitude and potential production characteristics of prospective resources. In some areas,

236companies may spend hundreds of millions of dollars per exploration project, in addition to the hundreds of millions of dollars invested to acquire leases. These costs consist of testing the prospective area via drilling, analyzing field and laboratory information and determining whether it is a viable commercial play. Releasing data to the publ ic too soon on such wells through the GHGRP

— despite the fact that they are held confidential by other regulatory bodies

— could cause substantial competitive harm and lead to a loss of investment value. Competitive advantage includes the ability to shield se nsitive information on a company’s operations including oil and gas reserve information on new wells, internally developed assessments of geologic prospects, drilling plans and interim results. Competitive harm may occur if the public can obtain detailed h igh resolution operational information on a well

- by

- well basis. The success of a well and of a particular play

— especially in exploratory areas

— could be inferred if detailed data is provided to the public too soon during the exploration and assessment perio d, and where according to state and federal laws the data is not already publicly available. An example of such an occurrence might be an exploratory well completed in December of the reporting year, reported to EPA by end of March of the following year an d then released by EPA to the public within a few months during the same year.
Foo tnotes:

1 43 CFR § 3162.8 Confidentiality (a) Information obtained pursuant to this part and on file shall be open for public inspection and copying during regular office ho urs upon a written request, pursuant to rules at 43 CFR part 2, except that: (1) Upon request, information obtained from an operating rights owner or operator under this part that constitutes trade secrets and commercial or financial information which is p rivileged or confidential or other information that may be withheld under the Freedom of Information Act (5 U.S.C. 552(b)), such as geologic and geophysical data and maps, shall not be available for public inspection or made public or disclosed without the consent of the operating rights owner or operator, as appropriate, for a period of 12 months; (2) Upon expiration of the 12

- month period, the operating rights owner or operator, as appropriate, may request that the data be held confidential for an additi onal 12

- month period; and (3) Upon termination of a lease, whether by expiration of its terms or otherwise, such information shall be made available to the public. [See at 47 FR 47765, Oct. 27, 1982. Redesignated and amended at 48 FR 36583

- 36586, Aug. 12 , 1983, further amended at 49 FR 37364, Sept. 21, 1984; 53 FR 17364, May 16, 1988]

2 Alaska State Code (AS 31.05.035) specifies procedures for “Confidential Reports”. Section (c) of the Alaska Code recognizes that: “... information required in (a) of this section that relate to an exploratory or stratigraphic test well and those portions of an application for a permit to drill an exploratory or stratigraphic test well that the commission determines contain proprietary engineering or geotechnical information shall be kept confidential for 24 months following the 30

- day filing period unless the owner of the well gives written permission to release the application and reports and information at an earlier date.“ (ii) Texas Administrative Code (title 16 part 1 ch apter 3, Oil and Gas) states in section (d) of rule 3.16: “(d) Delayed filing based on confidentiality. Each log filed with the commission shall be considered public information and shall be available to the public during normal business hours. If the ope rator of a well desires a log to be confidential, on or before the 90th day after the date a drilling operation is completed, the operator must submit a written request for a delayed filing of the log. When filing such a

237request, the operator must retain t he log and may delay filing such log for one year beginning from the date the drilling operation was completed. The operator of such well may request an additional filing delay of two years, provided the written request is filed prior to the expiration dat e of the initial confidentiality period. If a well is drilled on land submerged in state water, the operator may request an additional filing delay of two years so that a possible total delay of five years may be obtained.” Response: For five types of sit uations described in Section III.B of the preamble to the final rule, t he EPA has determined that early public disclosure of 12 data elements associated with wildcat wells and/or delineation wells could reveal the well productivity, thereby resulting in the loss of investment value. Thus, the final rule provides an option to delay reporting of these data elements for two reporting years. See Section III.B of the preamble to the final rule for a list of the situations under which a reporter may delay reporting for two years, the data elements for which a reporter may elect to delay reporting, and other requirements associated with th is option.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: API Requested Revisions to CBI Proposal. API requests

— consist ent with state and federal laws in oil producing states

— that EPA categorically determine that all information (with the exception of well ID and location), associated with exploratory wells , is to be classified as CBI for a period of at least 24 months. As addressed above, API’s confidentiality concerns for exploratory wells are related to the timing of releasing the information to the public. The situation of problematic early disclosure would occur acutely where an exploratory well is the sole well in a s ub

- basin category (including vertical or horizontal) and hence is not reported in combination with other wells which might help shield any individual well’s contribution. API does not expect more than a handful of such wells in any given year. API proposes that during such a 24 month period EPA provide CBI protection “across the board” for reporting for exploratory wells by allowing use of either one of the following two options: (i) Companies would report all data to EPA as mandated by Subpart W, but EPA w ill hold the reported data as CBI and not include it in its public data release for at least 24 months. This can be accomplished by a flagging system (or a “radio button”) in e

- GGRT that could also allow for a short informative text on why that particular well information is to be maintained confidential; or (ii) Companies would upload into the e

- GGRT system only exploratory wells ID and their location information and EPA would set up a deferral system where the remaining data would be backfilled by compani es after a period of 24 months.

238These approaches are workable in practice because they will not require case

- by

- case review of companies’ information, and they are consistent with the approach taken by states’ oil and gas commissions and are protective of companies’ commercial investment interests. In order to be responsive to EPA’s request, API provides in our technical comments section specific information on the data elements that API requests should be designated as CBI either for an initial 24 months f or exploratory wells or held confidential permanently in accordance with prior designations in other subparts of the GHGRP. API maintains that EPA should promulgate a final rule that affords CBI protection to the specified data elements in order to ensure that EPA’s requirements are in compliance with the law regarding protection of confidential business information and avoid risking antitrust ramifications for reporting companies. Response: As discussed in the response to c omment EPA

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. The EPA a lso agrees with the commenter that a two year dela y of reporting is sufficient to prevent early public disclosure

. See Section III.B of the preamble to the final rule for additional information about the requirements of the optio n to delay reporting for tw o years.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Confidentiality of Information for Exploratory Wells. EPA suggests that there is no need to protect the confidentiality of exploratory (or “step out”) wells because, according to EPA, the disclosure of data for onshore natural gas production at the sub

- basin level “would not be likely to reveal any proprietar y information about the facility or cost to do business.” With respect, EPA is simply wrong. By their very nature, exploratory wells are likely to be the only wells in a sub

- basin/county combination because they are testing new formations in an existing ar ea or new areas for hydrocarbon potential. Early release of information specific to exploratory wells may cause irreparable and substantive commercial and competitive harm to reporters. API believes that a 24 month period of data confidentiality treatment for public disclosure (not necessarily to EPA) would resolve issues regarding the release of information that may reveal proprietary and/or highly commercially sensitive information to competitors. Response: S ee response to comment EPA

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239Commenter Name: Carrie B. Crumpton Commenter Affiliation: CONSOL Energy, Inc. Document Control Number: EPA

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Comment: CONSOL requests that the EPA reconsider the requirement to report data for exploratory wells on the sub

- basin level. This information could be considered confidential business information and CONSOL requests that this info rmation continue to be reported on the basin level. Response: S ee response to comment EPA

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Commenter Name: Karin Ritte r Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: EPA should designate exploratory wells information as CBI and should maintain consistency of CBI designations amongst the GHGRP Subparts. API commented previously on CBI issues and these issues remain critically important. API has made clear that its major remaining concern with data confidentiality under Subpart W is the disclosure of information for exploratory wells, especially when they are located in stepout areas where no prior reporting exists for a given sub

- basin. We again provide comment on exploratory wells because this issue is of critical importance to the industry in order to avoid the di sclosure of sensitive, confidential and competitive business information prematurely to the public. Response: S ee response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: CBI Designations for Newly Proposed and Revised Data Elements. EPA is proposing CBI designations for newly proposed and revised data elements based on the categorical determinations it has developed previously for determining whether data elements are “CBI” or “not CBI” per the 2011 final rule. 9 The proposed expansion of the reporting requirements to include more detailed information on a daily or monthly basis, and by sub

- basin

240at the county level, has heightened the concern for the broad classification of such data elements as “not CBI” in all circumstances

. These concerns go beyond the previously discussed “inputs to emission equations” and include also data elements assigned to two data categories which EPA determined previously have to be assessed on “a case

- by

- case basis.” 10
EPA’s assertion that “disclos ure of data for onshore natural gas production at the sub

- basin level would not be likely to reveal any proprietary information about the facility or cost to do business,” 11 is not universally correct. This assertion ignores that exploratory wells

— by their very nature

— are likely to be the only wells in a sub

- basin/county combination because they are testing new formations, in an existing area, or new areas for hydrocarbon potential. By requiring reporting of all of these new data elements, without allowing at least a 24 month period of data confidentiality, EPA is requiring the release of information which will reveal proprietary and highly commercially sensitive information to competitors

-- even when this same information is protected under other federal a nd state laws and regulations.
Footnotes:

9 76 FR 30782, May 26, 2011, “Proposed Confidentiality Determinations for Data Required Under the Mandatory Greenhouse Gas Reporting Rule and Proposed Amendment to Special Rules Governing Certain Information Obtai ned Under the Clean Air Act.”

10 Alexis McKittrick and Mark De Figueiredo, EPA/CCD, EPA

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11 Alexis McKittrick and Mark De Figueiredo, EPA/CCD, EPA

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- 0064, February 20, 2014. Response: S ee response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Doc ument Control Number: EPA

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Comment: Proposed Citation Reference for Completions and Workovers with Hydraulic Fracturing: §98.236(g) and (g)(1), Proposed Rule Text: (g)...If your facility had gas well comp letions or workovers with hydraulic fracturing during the calendar year, then you must report information specified in paragraphs (g)(1) through (g)(10) of this section, for each sub

basin and well type combination. Report information separately for comple tions and workovers. (1) Subbasin ID.

241This is a CBI issue for exploratory wells where a new formation type or area is being evaluated. This information should remain confidential for a minimum of 24 months. Response: As discussed in Section III.B of the p reamble to the final rule, the EPA disagree s that the sub

- basin ID should remain confidential for two years . The sub

- basin ID (reported under § 98.236(g)( 1), (h)(1)(i), (h)(2)(i), and (m)(1)) and number of wells can be discerned from the well IDs, which are publicly available for all wells and provide the location of the well and the name of the drilling company. Since the location of the well can be discer ned from the well ID, the type of formation (reported under § 98.236(aa)(1)(ii)(C)) can be determined through publicly available information such as U.S. Geological Survey reports. Therefore, the EPA is finalizing as proposed the determination that the sub

- basin ID is not CBI

.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Completions and Wo rkovers without Hydraulic Fracturing: §98.236(h), (h)(1), and (h)(1)(i), Proposed Rule Text: (h)...If the facility had gas well completions or workovers without hydraulic fracturing, then you must report the information specified in paragraphs (h)(1) through (h)(4) of this section, as applicable. (1) For each sub

- basin with gas well completions without hydraulic fracturing and without flaring, report the information specified in paragraphs (h)(1)(i) through (h)(1)(vi) of this section. (i) Sub

- basin ID
This i s a CBI issue for exploratory wells where a new formation type or area is being evaluated. This information should remain confidential for a minimum of 24 months. Response: See the response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Completions and Workovers without H ydraulic Fracturing: §98.236(h)(2) and (h)(2)(i), Proposed Rule Text: (2) For each sub

- basin with gas well completions without hydraulic fracturing and with flaring, report the information specified in paragraphs (h)(2)(i) through (h)(2)(vii) of this secti on. (i) Sub

- basin ID. This is a CBI issue for exploratory wells. This information should remain confidential for a minimum of 24 months.

242Response: See the response to comment EPA

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Comment: Proposed Citation Reference for Associated Natural Gas Venting and Flaring: §98.236(m) and (m)(1), Proposed Rule Text: (m)...If associated gas was vented or flared during the calendar year, then you must report the information specified in paragraphs (m)(1) through (m)(8) of this section for each sub

- basin. (1) Subbasin ID. Previously reporting f or associated gas venting and flaring was at the Basin level. This change requires reporting at the sub

- basin level, which raises CBI concerns for exploratory wells. Associated gas identifies the well as an oil well. Response: See the response to comment EPA

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Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Completions and Workovers with Hydraulic Fracturing: §98.236(g)(2), Proposed Rule Text: Well type. This is a CBI issue for exploratory wells where a new formation type or area is being evaluated. This information should remain confid ential for a minimum of 24 months. Response: As discussed in Section III.B of the preamble to the final rule, the EPA disagrees that the well type should remain confidential for two years because the well type can be inferred from the formation type. As d iscussed in the response to comment EPA

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.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API)

243Document Control Number: EPA

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Comment: Proposed Citation Reference: 98.236(aa)(1)(ii)(C), Proposed Rule Text: Formation type. This is a CBI issue for exploratory wells

- it discloses the targeted formation. Response: As discussed in Section III. B of the preamble to the final rule, the EPA disagrees that the formation type should be confidential because the type of formation can be determined through publicly available USGS reports based on knowledge of the location of the well, which can be disce rned from the publicly available well ID. Therefore , the EPA is finalizing the determin ation as proposed that the formation type is not CBI.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 102
Comment: Proposed Citation Reference for Completions and Workovers with Hydraulic Fracturing: §98.236(g)(5) and §98.236(g)(5)(i), Proposed Rule Text: (5) If you used Equation W

- 10A to calculate annual volumetric total gas emissions, then you must report the information specified in paragraphs (g)(5)(i) and (g)(5)(ii) of this section. (i) Cumulative backflow time, in hours, for each sub basin (“Tp” in Equation W

- 10A). This is a CBI issue for explo ratory wells where a new formation type or new area is being evaluated. This information should remain confidential for a minimum of 24 months Response: As discussed in Section III.B of the preamble to the final rule, the EPA has determined that early pub lic disclosure of flowback time associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the loss of investment value. Therefore, in situations where wildcat wells and/or delineation wells are the only wel ls in a sub

- basin that can be used for the measurement of cumulative f low back time for gas well completions or workovers with hydraulic fracturing, the final rule provides reporters with the option to report this data element two years after the reporting year in which the data was collected. See Section III.B of the preamble to the final rule for additional information about the requirements of the option to delay reporting of this data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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244Comment: Proposed Citation Reference for Completions and Workovers with Hydraulic Fracturing: §98.236(g)(6), Proposed Rule Text: If you used Equation W

- 10B to calculate annual volumetric total gas emissions for completions that vent gas to the atmosphere, then you must report the vented natural gas volume, in standard cubic feet, for each well in the sub

- basin (“FVs,p” in Equation W

- 10B). This is a CBI issue for exploratory wells. This information should remain confidential for a minimum of 24 months. Response: As discussed in Section III.B of the preamble to the final rule, the EPA disagree s that the vented natural gas volume for completi ons and workovers with hydraulic fracturing should remain confidential for two years

. This data element meets the definition of emission data in 40 CFR 2.301(a)(2)(i) because they are actual GHGs emitted by the facility. Under CAA section 114(c), the EPA m ust make available emission data, whether or not such data are CBI. For these data elements that are assigned to the “Emissions” data category, the commenter did not claim or provide any justification for why these data elements do not meet the definition of emission data.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citation Reference for Completions and Worko vers with Hydraulic Fracturing: §98.236(g)(7), Proposed Rule Text: Annual gas emissions, in standard cubic feet (“Es,n” in Equation W

- 10A or W

- 10B). This is a CBI issue for exploratory wells. This information should remain confidential for a minimum of 24 months. Response: As discussed in Section III.B of the preamble to the final rule, the EPA disagrees that annual gas emissi o ns should remain confidential for two years. This data element meets the definition of emission data in 40 CFR 2.301(a)(2)(i) becau se they are actual GHGs emitted by the facility. Under CAA section 114(c), the EPA must make available emission data, whether or not such data are CBI. For these data elements that are assigned to the “Emissions” data category, the commenter did not claim or provide any justification for why these data elements do not meet the definition of emission data.

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245Comment: Proposed Citation Reference for Completions and Workovers without Hydraulic Fracturing: §98.236(h)(1)(iv), Proposed Rule Text: Average daily gas production rate for all completions without hydraulic fracturing in the sub

- basin without flaring, in standard cubic feet per hour (average of all “Vp” used in Equation W

- 13B). This is a CBI issue for exploratory wells

– it discloses the daily gas flow rate. This information should remain confidential for a minimum of 24 month s
. Response: As discussed in Section III.B of the preamble to the final rule, the EPA has determined that early public disclosure of this data element associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the loss of investment value. Therefore, in situations where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the measurement of the average daily gas production rate for all completions without hydraulic fr acturing, the final rule provides reporters with the option to report this data element two years after the reporting year in which the data was collected. See Section III.B of the preamble to the final rule for additional information about the requirement s of the option to delay reporting of this data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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Comment: Proposed Citat ion Reference for Completions and Workovers without Hydraulic Fracturing: §98.236(h)(2)(iv), Proposed Rule Text: Average daily gas production rate for all completions without hydraulic fracturing in the sub

- basin with flaring, in standard cubic feet per ho ur (the average of all “Vp” from Equation W

- 13B. This is a CBI issue for exploratory wells

– it discloses the daily gas flow rate. This information should remain confidential for a minimum of 24 months. Response: As discussed in Section III.B of the pream ble to the final rule, the EPA has determined that early public disclosure of this data element associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the loss of investment value. Therefore, in situatio ns where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the measurement of the average daily gas production rate for all completions without hydraulic fracturing, the final rule provides reporters with the opt ion to report this data element two years after the reporting year in which the data was collected. See Section III.B of the preamble to the final rule for additional information about the requirements of the option to delay reporting of this data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API)

246Document Control Number: EPA

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Comment: Proposed Citation Reference for Onshore Production Storage Tanks: §98.236(j)(2) and (j)(2)(i) and (j)(2)(i)(A), Proposed Rule Text: (2) If you used Calculation Method 3 to calculate GHG emissions, then you must report the information specified in paragraph (j)(2)(i) through (j)(2)(iii) of this paragraph. (i) Report the i nformation specified in paragraphs (j)(2)(i)(A) through (j)(2)(i)(F) of this section at the basin level for atmospheric tanks where emissions were calculated using Calculation Method 3. (A) The total annual oil throughput that is sent to atmospheric tanks in the basin, in barrels. Revised from: “Total volume of oil production in barrels per year.” It is possible that an exploratory well could be evaluating an entirely new sub

- basin, in which case this information would be CBI. Response: For the reasons des cribed in Section III.B of the preamble to the final rule, the EPA has determined that early public disclosure of this data element associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the loss of inve stment value. Therefore, in situations where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the measurement of the total annual oil throughput that is sent to atmospheric tanks , the final rule provides reporte rs with the option to report this data element two years after the reporting year in which the data was collected. See Section III.B of the preamble to the final rule for additional information about the requirements of the option to delay reporting of thi s data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 112
Comment: Proposed Citation Reference for Well Testing: §98.236(l )(1)(iv), Proposed Rule Text: If oil well testing is performed where emissions are not vented to a flare, the average flow rate in barrels of oil per day for well(s) tested. This is a CBI issue for exploratory wells

- it discloses oil flow rate. This inform ation should remain confidential for a minimum of 24 months. Response: For the reasons described in Section III.B of the preamble to the final rule, the EPA has determined that early public disclosure of this data element associated with wildcat wells and /or delineation wells could reveal well productivity, thereby resulting in the loss of investment value. Therefore, in situations where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the measurement of the ave rage daily oil flow rate , the final rule provides reporters with the option to report this data element two years after the reporting year in which the data was collected. See Section III.B of the preamble to the final rule

247for additional information about the requirements of the option to delay reporting of this data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 113
Comment: Proposed Citation Reference for Well Testing:§98.236(l)(2)(iv), Proposed Rule Text: If oil well testing is performed where emissions are vented to a flare, the average flow rate in barrels of oil per day for well(s) tested.
This is a CBI issue fo r exploratory wells

- it discloses oil flow rate. This information should remain confidential for a minimum of 24 months. Response: For the reasons described in Section III.B of the preamble to the final rule, the EPA has determined that early public discl osure of this data element associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the loss of investment value. Therefore, in situations where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the measurement of the average daily oil glow rate , the final rule provides reporters with the option to report this data element two years after the reporting year in which the data was collected. See Section III.B of the preamble to the final rule for additional information about the requirements of the option to delay reporting of this data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 114
Comment: Proposed Citation Reference for Well Testing:§98.236(l)(3)(iii), Proposed Rule Text: If gas well testing is performed where emissions are not vented to a flare, the average annual production rat e in actual cubic feet per day for well(s) tested. This is a CBI issue for exploratory wells

- it discloses gas flow rate. This information should remain confidential for a minimum of 24 months. Response: For the reasons described in Section III.B of the p reamble to the final rule, the EPA has determined that early public disclosure of this data element associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the loss of investment value. Therefore, in situ ations where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the measurement of the average annual gas production rate , the final rule provides reporters with the option to report this data element two

248years af ter the reporting year in which the data was collected. See Section III.B of the preamble to the final rule for additional information about the requirements of the option to delay reporting of this data element.

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- A2 Error! Bookmark not defined. Comment Excerpt Number: 115
Comment: Prop osed Citation Reference for Well Testing:§98.236(l)(4)(iii), Proposed Rule Text: If gas well testing is performed where emissions are not vented to a flare, the average annual production rate in actual cubic feet per day for well(s) tested.
This is a CBI i ssue for exploratory wells

- it discloses gas flow rate. This information should remain confidential for a minimum of 24 months. Response: For the reasons described in Section III.B of the preamble to the final rule, the EPA has determined that early publi c disclosure of this data element associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the loss of investment value. Therefore, in situations where wildcat wells and/or delineation wells are the only w ells in a sub

- basin that can be used for the measurement of the average annual gas production rate , the final rule provides reporters with the option to report this data element two years after the reporting year in which the data was collected. See Sectio n III.B of the preamble to the final rule for additional information about the requirements of the option to delay reporting of this data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control N umber: EPA

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- A2 Comment Excerpt Number: 117
Comment: Proposed Citation Reference for Associated Natural Gas Venting and Flaring: §98.236(m)(2), Proposed Rule Text: For each sub

- basin, indicate whether any associated gas was vented wi thout flaring. Previously reporting for associated gas venting and flaring was at the Basin level. This change requires reporting at the sub

- basin level, which raises CBI concerns for exploratory wells. Associated gas identifies the well as an oil well

. Response: If exploratory wells are the only wells in a sub

- basin, the commenter is concerned that reporting any information related to associated gas emissions (such as whether the emissions are vented without flaring) identifies the wells as oil wells. A s discussed in the response to

249comment EPA

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- A2, Excerpt 132 of this section and in Section III.B of the preamble to the final rule, the EPA disagree s that the well type should be confidential because it can be inferred from the publicl y available well ID, location, and type of formation. Since the well type is not confidential, EPA also disagrees that information about associated gas emissions should be confidential. Thus, the EPA is finalizing th e determination as proposed that indicat ing whether any associated gas was vented without flaring is not CBI.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 118
Comment: P roposed Citation Reference for Associated Natural Gas Venting and Flaring:§98.236(m)(3), Proposed Rule Text: For each sub

- basin, indicate whether any associated gas was flared. Comment: Previously reporting for associated gas venting and flaring was at the Basin level. This change requires reporting at the sub

- basin level, which raises CBI concerns for exploratory wells. Associated gas identifies the well as an oil well. Response: If exploratory wells are the only wells in a sub

- basin, the commenter is concerned that reporting any information related to associated gas emissions (such as whether the emissions are flared) identifies the wells as oil wells. As discussed in the response to comment EPA

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- A2, Excerpt 132 of this section and in Section III.B of the preamble to the final rule, the EPA disagrees that the well type should be confidential because it can be inferred from the publicly available well ID, locati on, and type of formation. Since the well type is not confidential, EPA also disagrees that information about associated gas emissions should be confidential. Thus, the EPA is finalizing the determination as proposed that indicating whether any associated gas was flared is not CBI.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 119
Comment: Proposed Citation Reference for Associated Natural Gas Venting and Flaring:§98.236(m)(5), Proposed Rule Text: Volume of oil produced, in barrels, in the calendar year during the time periods in which associated gas was vented or flared (the sum of “Vp,q” used in Equation W

- 18 of this subpart).
Pre viously reporting for associated gas venting and flaring was at the Basin level. This change requires reporting at the sub

- basin level, which raises CBI concerns for exploratory wells. Associated gas identifies the well as an oil well.

250Response: For the r easons described in Section III.B of the preamble to the final rule, the EPA has determined that early public disclosure of this data element associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the lo ss of investment value. Therefore, in situations where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the measurement of volume of oil produced , the final rule provides reporters with the option to report this data element two years after the reporting year in which the data was collected. See Section III.B of the preamble to the final rule for additional information about the requirements of the option to delay reporting of this data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 120
Comment: Proposed Citation Reference for Associated Natural Gas Venting and Flaring:§98.236(m)(6) , Proposed Rule Text: Total volume of associated gas sent to sales, in standard cubic feet, in the calendar year during time periods in which associated gas was vented or flared (the sum of “SG” values used in Equation W

- 18 of this subpart). Previously rep orting for associated gas venting and flaring was at the Basin level. This change requires reporting at the sub

- basin level, which raises CBI concerns for exploratory wells. Associated gas identifies the well as an oil well. Response: For the reasons desc ribed in Section III.B of the preamble to the final rule, the EPA has determined that early public disclosure of this data element associated with wildcat wells and/or delineation wells could reveal well productivity, thereby resulting in the loss of investment value. Therefore, in situations where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the measurement of total volume of associated gas sent to sales , the final rule provides reporters with the optio n to report this data element two years after the reporting year in which the data was collected. See Section III.B of the preamble to the final rule for additional information about the requirements of the option to delay reporting of this data element.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 134
Comment: Proposed Citation Reference: §98.236(aa)(1)(ii)(G), Proposed Rule Text: For each sub

- basin category, the number of wells completed during the calendar year.

251Comment: This is a CBI issue for exploratory wells

- it discloses the targeted formation and the success in finding hydrocarbon

. Response: For the reasons described in Sec tion III.B of t he preamble to the final rule, EPA disagree s that public disclosure of the number of wells completed in a sub

- basin during the time period immediately following annual reporting would cause substantial competitive harm to reporters. As we no te in the preamble, this data element provides information that is either already in the public domain or easily inferred from other publicly available data. For these reasons, EPA is finalizing the determin ation as proposed that this data element is not C BI.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 133
Comment: Proposed Citation Reference: §98.236(aa)(1)(ii)(D), Proposed Rule T ext: For each sub

- basin category, the number of producing wells at the end of the calendar year. Comment: This is a CBI issue for exploratory wells

- it discloses the targeted formation. Response: For the reasons described in Section III.B of the preamble to the final rule, EPA disagree s that public disclosure of the number of producing wells during the time period immediately following annual reporting would cause substantial competitive harm to reporters. As we note in the preamble, this data element prov ides information that is either already in the public domain or easily inferred from other publicly available data. For these reasons, EPA is finalizing the determin ation as proposed that this data element is not CBI.



### 23.0 I mpacts of the Proposed A mendments

Com menter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 68
Comment: For reporting of proposed new data elements, EPA assumed that 3 minutes would be required to find, document, and report each new data element: "The EPA then multiplied the adjusted number of new and revised data elements by 3 minutes per data element

— the amount time that the EPA estimated an engineer would need to a ccess the data element from readily available data [Emphasis added] and submit the value..." (AI page 8) This estimate does not consider the level of effort required to determine who collects such data, how it is documented (e.g., records in a database or hard files, multiple potential data systems to

252assess), associated Subpart W recordkeeping, revising data collection systems and templates, etc. It appears to assume that some sort of simple company

- level database search is conducted for each data new elem ent. Estimates of incremental effort should consider the number of hours, rather than minutes, per data element, and EPA likely under

- estimates implementation costs by two or more orders of magnitude. An INGAA member estimated that the company

- wide impleme ntation of system revisions to identify, collect, document, and report the new data elements will be $150,000 or more, with additional ongoing annual costs to fulfill the reporting obligation for the new data elements.

• It is inconceivable that data review and oversight costs would exceed the costs to gather the data, develop new systems to accommodate the data, quality assure the data, perform calculations, report the data, and follow

- up on questions that may be asked. EPA estimates its costs, and estimates that EPA’s incremental costs for the proposed Subpart W revisions for EPA for the first three years will include about $436,000/yr for headquarters oversight and implementation, plus $783,000/yr for third party verification for a total of about $1,200,000 /yr. EPA estimates the incremental cost for Industry/Public will be about $543,000 per year for the first three years. Thus, EPA estimates that the Proposed Rule will cost EPA more than twice the cost incurred by the 2,000+ reporting facilities for the Pet roleum and Natural Gas Systems Industry. (ICR Pages 12

– 15).

• EPA estimates the average total (not incremental) annual number of hours for each facility to comply with Subpart W is 53.5 (hr/yr).

− "The annual public reporting and recordkeeping burden for t his collection of information is estimated to average 53.5 hours per response." (ICR page 21) This is an absurdly low estimate of the level of effort required for rule implementation that includes planning and coordination, training, data collection includ ing direct measurements and validation, running software simulations, performing calculations, recordkeeping, and reporting.

• EPA acknowledges the definition of ‘burden’ from the Paperwork Reduction Act but it does not appear that EPA considered each elemen t when developing the estimated costs for Industry. "Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a federal agency. This includes the time needed to review instructions ; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information , processing and maintaining information, and disclosing and providing information; adjust the exist ing ways to comply with any previously applicable instructions and requirements ; train personnel to respond to a collection of information ; search data sources ; complete and review the collection of information ; and transmit or otherwise disclose the information." 11 ( emphasis added ) There are additional examples in the impact assessments. The general theme is consistent: EPA significantly under

- estimates costs and impacts to the affected community. Implementation burden should be assessed when justifyi ng rule requirements; the erroneous estimates fail to fulfill that obligation. In considering INGAA’s comments and responses necessary to complete

253the final rule, EPA should reassess under

- estimated industry cost impacts to meet its obligation to justify d ecisions reflected in Subpart W.
Footnote:

11 “Information Collection Request for the Greenhouse Gas Reporting Program,” EPA

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.

Commenter Name: V. Bruce Thompson Commenter Affiliation: American Exploration & Production Council (AXPC) Document Control Number: EPA

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- A2 Comment Excerpt Number: 1
Commen t: The proposed rule adds large amounts of additional data collection and reporting requirements that AXPC and the Alliance believe to be unduly burdensome and difficult to implement. Although considered, EPA has vastly underestimated the amount of time t hat is needed in order to modify data collection, management, and reporting systems and processes. Data reported for the rule is often compiled from a number of different systems and the addition of each data element will require an evaluation of where the data can be pulled from, how it can be integrated into current data management systems and processes, and how it can be integrated into existing raw data reporting formats. This process will take many man

‐ hours per data element, vastly more that the EPA e stimate of three minutes per element. Response: See Section IV.B of the preamble to the final rule for discussion related to this comment.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 147
Comment: In its February 20, 2014, memo to the docket entitled, Assessment of Impacts of the 2014 Proposed Revisions to Subpart W [ Alexis McKittrick and Mark de Figueiredo, EPA/CCD, “Assessment of Impacts of the 2014 Proposed Revisions to Subpart W”, EPA

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- 0063, February 20, 2014], EPA addresses the potential burden to reporters. EPA admits that it is proposing that 245 new data elements be reported and that 15 data elements will r emain but must be substantially revised which will “impose additional burden and costs because, for each of the new and revised data elements that would be required to be reported, reporters would be required to calculate the data using readily available d ata, and report the value to the EPA via [e

- GGRT] as part of the annual report currently required under Part 98.” EPA then calculated the

254burden associated with the new and revised data elements by adjusting labor hours upward per reporter for all industry segments. EPA’s calculations, however, vastly underestimate the labor time and the overall burden and there is no discussion explaining how EPA “adjusted” its numbers (other than explaining that EPA looked at costs through the lens of labor costs) to get the numbers provided in the memo that simply do not account for the actual burdens on the reporters particularly with the tremendous expansion of data recording requirements. On page 8 of the memo, EPA estimated that an engineer would require 3 minutes per data element to access each new data element from “readily available data” and submit the value via e

- GGRT. The EPA fails to realize that in many cases, each data element may not be stored in a central database and each engineer compiling the data for sub mittal to e

- GGRT would potentially need to network with several different company employees or sources to even access the information. The engineer would also have to make determinations regarding each of the data elements to assure that the data provided indeed matches the precise requirements that the EPA is requesting. Data would also then need to be compiled together by each data element and sub

- basin as required (e.g. totaled or averaged), reviewed, and inserted into the e

- GGRT forms. Each one of these steps alone would take more than three minutes per element. In cases where a newly required data element is stored at the local level, the time spent compiling the data could stretch by hours, if not days. EPA’s assumption that all the newly required data elements could be accessed from a central database, by an engineer familiar with the data set and its quality, then pulled, compiled, reviewed and input into the e

- GGRT forms in three minutes is not a realistic estimate based on the quantity and variety o f data requested. Even if the data were already available and easily accessible in one central database, a significant amount of time would be required to identify each piece of information in the database to match up with the EPA’s list of data elements a nd make necessary modifications to reports used to extract and properly aggregate the information for each data element in a reportable format. API is ready to continue this discussion on burden estimates with EPA. Response: Regarding the EPA's justificat ion for the additional reporting elements in this rulemaking, see Section II.E.2 of the preamble to the final rule. Regarding the EPA’s response to the comment on the compliance costs associated with data reporting, see Section IV.B of the preamble to the final rule. Also, discussion explaining how the EPA determined the number of data elements per industry segment has been added to “Final Assessment of Impacts of the 2014 Revisions to Subpart W” (see Docket Id. No. EPA

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Commenter Name: Ritu Talwar Commenter Affiliation: Spectra Energy Corp Document Control Number: EPA

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- A1 Comment Excerpt Number: 3
Comment: New Reporting Elements to Calculate GHG Emissions EPA has arbitrarily added new reporting elements that are not needed to calculate GHG emissions. We refer you to INGAA ’ s comments for a comprehensive list of these elements. EPA has significantly under

- estimated Subpart W compliance costs, including costs associated with data compilation and reporting. It is important that EPA understands there are real and

255substantive costs for implementing systems to collect and report new data that are not needed to calculate GHG emissions, and these costs should be adequately considered and weighed against the purpose and value of the new data to be collected. EPA should provide the justification for adding new reporting elements to this rule

- making. Response: Regarding the EPA's justification for the additional reporting elements in this rulemaking, see Section II.E.2 of the preamble to the final rule. Regarding the EPA’s response to the comment on the compliance costs associated with data reporting, see Section IV.B of the preamble to the final rule.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 58
Comment: EPA has significantly under

- estimated Subpart W implementation costs, including costs associated with data compilation and reporting. For example, review of proposed new data elements by an INGAA member estimated that it would require 1,000 hours per year to track and report for their subject T&S facilities. In addition, systems would need to be established to reduce human tra cking error. The cost of creating or adding data elements could cost an additional $100,000 per year to implement and maintain. It is important that EPA understands there are real and substantive costs for implementing systems to report new data, and these costs should be adequately considered and weighed against the purpose and value of the new data to be collected. Response: Overall, the EPA has determined that the commenters do not take into consideration the completion of one

- time activities during the first year of data collection, such as planning, registration, installing required equipment, and developing a data tracking system

. See Section IV.B of the preamble to the final rule for EPA's response to this comment.

Commenter Name: Karin Ritter Comm enter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 13
Comment: Significant Expansion of Reporting Requirements. If EPA adopts the proposed rule with respect to certain rep orting requirements, the final rule will significantly expand reporting requirements for some sources and require additional data collection that was not previously required. EPA should not utilize this proposed rule as an opportunity to further expand rep orting requirements and introduce new burdens on the regulated industry at this stage. Additionally, in its rule impact memorandum, in which the agency assesses impacts on reporters, EPA vastly underestimates the time and burden of these expanded requireme nts.

256Response: Regarding the EPA's justification for the additional reporting elements in this rulemaking, see Section II.E.2 of the preamble to the final rule. See Section IV of the preamble to the final rule for more detailed discussion of the impacts o f the final amendments and the EPA’s response to this comment

.

Commenter Name: Carrie B. Crumpton Commenter Affiliation: CONSOL Energy, Inc. Document Control Number: EPA

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- A1 Comment Excerpt Number: 1
Comment: The rule itself is generally already too expansive with regards to data collection and reporting and the proposed rule further expands the data collection and reporting requirements for some sources. These requirements will be both burdensome and could lead to a substantial cost to the industry. CONSOL Energy Inc. (CONSOL) requests that the Environmental Protection Agency (EPA) reconsider these additional requirements. CONSOL has invested in a robust system to manage data collection and reporting requirements per the origina l rule and continuing changes to implement and reconfigure data management systems become burdensome and costly. Examples of these new or expanded requirements include:

• Expanding the reporting requirements for emissions at stuck dump valves to tanks with l ess than 10 bbl/day throughput.

• Expanding the data collection and reporting requirements for well type combinations that include completions and workovers to additionally include with/without flaring and with/without reduced emission workovers. Potentially doubling measurement and reporting requirements.

• Expanding the definition of well type combinations for workovers to include with and without reduced emission workover. This potentially quadruples the measurement and reporting requirements. Response: The EPA appreciates the commenter's concern over the complexity and burden of the subpart W requirements for calculating and reporting GHG emissions. The EPA has revised certain calculation methods and amended certain monitoring and data reporting requirements in the final rule as a result of public comments

. The EPA has also provide d additional flexibility for certain monitoring and calculation requirements. For example, it was not the EPA’s intent to require reporting of emissions from stuck dump valves to storage tanks with a throughput less than 10 barrels per day and therefore the EPA has revised the final rule accordingly , as noted in Section II.B.7 of the preamble to the final rule. In many cases, the revisions that are being made improve the estimating and reporting of GHG emissions and reduce the burden on those facilities required to report GHG emissions. Regarding the data collection and reporting requirements for gas well completions and workovers and the revised definition of well type co mbinations, the EPA is finalizing these provisions as p roposed. We disagree with comme n t ers that the requirements will impose a significant burden on reporters, because it is unlikely that reporters conduct drilling activities in

257all the different types of wells for a given sub

- basin . See Section II.B.5 of the preamble to the final rule for additional information.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Association of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 22
Comment: EPA documents assessing costs to conduct compressor measurements and implement other Proposed Rule requirements are inadequate. Implementation costs are under

estimated by an order of magnitude or more , which suggests the authors lack a fundamental understanding of both the type of activities and level of effort required to collect data for Subpart W reporting. The Proposed Rule docket includes two documents that address incremental costs associated wit h the proposed Subpart W revisions:

• EPA

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• EPA

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- 0066: ICR Supporting Statement (hereafter referred to as "ICR") In general, the documents greatly over

- simplify the impact of the Proposed Rule and under

estimate the associated incremental costs. Following is a partial sampling (i.e., not every issue is addressed) of EPA estimates of incremental costs associated with pro posed Subpart W revisions that appear to be severely under

- estimated (e.g., by one to two orders of magnitude or more), and other information and data associated with the estimates.

• Many of the EPA estimated incremental costs for reporters associated with the proposed Subpart W revisions are severely under

- estimated. Examples include:

- Regarding incremental management support for Proposed Rule revisions, EPA states: "None of the proposed amendments require an adjustment to middle and senior management labo r hours" (AI page 1). The cost estimates do not include management tasks including review of the proposed rule and final revisions, Monitoring Plan revisions, internal communications, coordination with technical staff, training, systems updates, associated budgeting and planning, etc. EPA estimated that for compressor stations with manifolded compressor sources, the cost of annual compressor source gas emission measurements would decrease because one measurement (at the manifold) would be conducted rather than a measurement at each compressor source. "This proposed change is a burden reduction for reporters that have more than three compressor sources manifolded together" (AI page 3)

258This analysis fails to consider that manifolded vents would require three separate measurements (i.e., three separate trips to a compressor station) separated by a minimum of 60 days during the calendar year. EPA fails to consider the costs associated with each separate measurement/trip including test personnel scheduling and fa cility coordination, mobilization (equipment preparation, travel to and from the facility), on

- site set up, daily safety orientation, man

- lift rental, operations staff support, etc. Further, the EPA cost analysis assumes an incremental time of 10 minutes f or a technician to conduct each additional compressor source measurement. That is, to conduct blowdown valve leakage measurements on four compressors would require 30 minutes more than conducting blowdown valve leakage measurements on a single compressor. This fails to consider the time required to move personnel and equipment (likely including a man lift or a ladder) from compressor to compressor in the tight confines of a compressor station, and the cautious pace of work and work practices (e.g., use of l anyard and/or other fall protection) for safely working at elevated locations. Finally, this 10 minute per measurement estimate appears to assume that the technician is working alone. Personnel working at elevated locations should never work without assist ance. This time allotment also fails to consider all of the time associated with logistics and mobilization discussed above (AI page 3). In contrast, compressor source measurement cost estimates provided by INGAA members range from about $1,300 to $3,000+ per facility per test (i.e., these incremental costs would be incurred at least two times a year) . Actual costs would depend on numerous parameters including number of manifolded compressor sources and accessibility, test team travel time and costs, number of test team members, and number of facilities that can be visited by a test team in a single mobilization. Further, these costs are only for the testing contractor and do not include facility and company costs including scheduling, coordination, test tea m support, burden, etc. As an alternative, EPA may have assumed that tests would be conducted by staff on site. This fails to understand that annual surveys are typically completed by third party contractors. Even for companies that have increased staff to conduct the Subpart W measurements, there would be dedicated teams that move from station to conduct the measurements, similar to conducting the measurements using third party contractors. It would be cost prohibitive to equip and train personnel at every compressor station to conduct the Subpart W monitoring based on the substantial costs associated with equipment acquisition (e.g., infrared cameras, high volume samplers, and other meters and equipment required to conduct the Subpart W monitoring), and th e specialized training that differs from current skill sets and would thus require ongoing oversight. In the preamble, EPA states, "This proposed measurement option would allow the EPA to correctly characterize and analyze GHG emissions from all compressor s at individual facilities in the petroleum and natural gas systems source category while potentially reducing burden to industry." This requirement would not reduce burden to industry; instead, it adds two additional annual measurement trips in perpetuity

. Response: We have revised the final rule to require only a single annual emissions measurement at the common vent for groups of manifolded compressors. The incremental time measurements assumed that the level of effort associated with manifolded measure ments are

259similar to the level of effort associated with measurements for individual compressors. See Section IV of the preamble to the final rule for more information

.

Commenter Name: Lisa Beal Commenter Affiliation: Interstate Natural Gas Associatio n of America (INGAA) Document Control Number: EPA

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- A1 Comment Excerpt Number: 23
Comment: Regarding incremental costs associated with proposed revised requirements for Blowdown Vent Stacks, EPA states: "The EPA is proposing to add a compressibility term to the blowdown vent stack calculations. It is anticipated that reporters handle gas within the proposed compressibility factor default ranges; therefore, it is unlikely that adding this compressibility factor term into the blowdown v ent stack calculations would increase burden to reporters. Therefore, the EPA did not estimate the potential burden impact to reporters for this change." (AI page 6) Processing, transmission, and storage facilities all handle gas with compressibility outsi de the proposed compressibility factor default range of less than 5 atmospheres (73.5 psi). Operating pressures commonly exceed 74 psi, for segments required to complete blowdown vent reporting. This is another example of EPA’s fundamental lack of understa nding of natural gas system operations for the two primary segments (processing, transmission) that are required to report blow downs. EPA’s estimate of the Proposed Rule implementation costs (i.e., zero) is obviously grossly underestimated. Further, this statement directly conflicts with information and data considered by EPA in the Technical Support Document. "The natural gas processing and transmission compression segments covered by subpart W can operate systems at pressures higher than 25 atmospheres." "Natural gas transmission compressor station components and main line pressures are in the range of 500 to 1000 psi (34 to 68 atmospheres). See page 6

- 32, American Petroleum Institute (August 2009), Compendium of Greenhouse Gas Emission Methodologies for the Oil and Natural Gas Industry ." Indeed, because of this pressure limitation of less than 5 atmospheres, and because of typical operating pressures at these facilities, reporters will almost always have to calculate the compressibility factor. Even if th e factor at actual conditions is greater than 0.98 (where EPA proposes to allow the reporter to use the default factor of 1), the reporter must still undergo the burden of determining whether the factor is above 0.98. Response: We have revised the final r ule to allow reporters the option to use a default compressibility factor of 1 or use a site

- specific factor based on actual temperature and pressure conditions . See Section II.B.6 of the preamble to the final rule for additional discussion regarding the optional use of compressibility factors

. Because the final rule does not mandate the use of a site

- specific compressibility factor, we have determined that adding this optional

260compressibility factor term into the blowdown vent stack calculations will not increase burden to reporters.

Commenter Name: Gary W. Smith Commenter Affiliation: Document Control Number: EPA

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- 0072 Comment Excerpt Number: 2
Comment: The basis for monitoring these gasses is predominately conditioned on non
- scientific modeling provided by a UN agency which is hostile to the Constitution and the principles on which this nation was founded. The imposition of these changes provides no improvement to the individual nor the nation's character and processes, is as worthless as the onerous regulatory conditions imposed by other ill

- planned controls, the most predominant example being Sarbanes

Oxley. In a time of negligible economic growth, the added cost burdens both the industry and the citizen with no gain to t he industry on which human survival is critical. At the rate of destruction of the energy grid sustaining industries with no successful replacement in development, the EPA is dooming citizens during planet cycles when the northern hemisphere is coldest, lo oting their treasure to obtain sustaining warmth, and in general, wrecking havoc. It is as if EPA regulatory demands wish to fulfill the tasks assigned to one of the four horsemen of the apocalypse. While I am not a person of scientific stature, reasoned b ehavior by Government is not demonstrated in this regulatory update. The following list of scientists do not concur with 'Climate Change', a driver of this regulatory development, as do I, and, have provided credible research into the folly and unscientifi c nature of any such type of destructive regulatory management as imposed in 40 CFR Part 98: Craig D. Idso (USA), Robert M. Carter (Australia), S. Fred Singer (USA), Timothy Ball (Canada), Robert M. Carter (Australia), Don Easterbrook (USA), Craig D. Idso (USA), Sherwood Idso (USA), Madhav Khandekar (Canada), William Kininmonth (Australia), Willem de Lange (New Zealand), Sebastian Lüning (Germany), Anthony Lupo (USA), Cliff Ollier (Australia), Willie Soon (USA), J. Scott Armstrong (USA), Joseph D’Aleo (USA ), Don Easterbrook (USA), Kesten Green (Australia), Ross McKitrick (Canada), Cliff Ollier (Australia), Tom Segalstad (Norway), Dr. Roy Spencer (USA), Habibullo Abdussamatov (Russia), Joe Bastardi (USA), Franco Battaglia (Italy), David Bowen (UK), Roy Clark (USA), Vincent Courtillot (France), Christopher Essex (Canada), David Evans (Australia), Sören Floderus (Denmark), Stewart Franks, (Australia), Eigil Friis

- Christensen (Denmark), Fred Goldberg (Sweden), Larry Gould (USA), William Gray (USA), Richard Gray (New Zealand), Howard Hayden (USA), Martin Hovland (Norway), Olavi Kärner (Estonia), James O’Brien (USA), Garth Paltridge (Australia), Donald Rapp (USA), Carl Ribbing (Sweden), Nicola Scafetta (USA), John Shade (UK), Gary Sharp, (USA), Jan

- Erik Solheim (No rway), Antón Uriarte Cantolla (Spain), Gerd Weber (Germany). This is but a short

- list. Response: The EPA thanks the commenter for their input. We have determined that t he final amendments to subpart W do not significantly increase the burden of data colle ction. In general, these revisions provide greater flexibility for reporters and increase the clarity and congruency of

261the calculation and reporting requirements. See Section IV of the preamble to the final rule for more detailed discussion of the impacts of the final amendments

.


### 24.0 Out of Scope Comments: General Comments Outside of the Scope of the Amendments The EPA received the following comments, which do not specifically address the proposed rule and are beyond the scope of this rulemaking. Therefore, the EPA is not responding to these comments in this document.
Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

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- A2 Comment Excerpt Number: 10
Comment: We respectfully urge the Agency to strengthen Subpart W in other important ways identified in the March 2013 petition. As noted, it has been over a year since this petition was submitted to EPA, we have had no response from the Agency on several time sensitive requests se t out in the petition, and we believe the Agency’s failure to respond is unreasonable. Accordingly, we respectfully urge EPA to take immediate action in response to the March 2013 petition. Specifically, we requested that the Agency require reporting from facilities and pipelines in the gathering and boosting segments, as well as from transmission pipeline blowdown events. We also asked that reporters include American Petroleum Institute well identification numbers with all data submissions. Finally, we res pectfully urged EPA to promote Advanced Innovative Monitoring Methods (“AIMM”) to further the use of real

- time continuous methane emissions monitoring. We believe this is an essential element of a well

- designed GHG emissions inventory and reporting program for the oil and gas sector. Promoting AIMM could be readily effectuated by incorporating into the final Subpart W revisions a mechanism for any member of the public to request improvements to the oil and gas emissions reporting program based on new monito ring technologies and a commitment by the Agency to promptly act on such requests. We also recommend that EPA incorporate final revisions into this rule that set out a commitment by the Agency to conduct regular reviews to assess whether new oil and gas mo nitoring technologies are available that could be incorporated into the program. Response: The EPA thanks the commenter for their input. The commenter's suggestion for further revisions to subpart W, including reporting from facilities in the gathering an d boosting segments and from transmission pipeline blowdown events, collecting API well ID numbers for all data, and requiring the use of the commenter described a dvanced i nnovative m onitoring
m ethods, these comments are beyond the scope of this rulemaking

. However, the EPA may consider the commenter’s suggestions in a future rulemaking

.

262Commenter Name: Brian Korpics Commenter Affiliation: Environmental Defense Fund Document Control Number: EPA

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- A2 Comment Excerpt Number: 9
Commen t: EPA has proposed to revise the definition of sub

- basin category found in 40 C.F.R. § 98.238 in order to clarify that “tight gas reservoir rock” generally refers to tight reservoir rock formations that produce gas

— not those formations that only produce oil. The rule also updates the regulation so that all wells that produce hydrocarbon liquids (with or without gas) but do not meet the definition of “gas well” contained in the regulation would be categorized as part of the oil formation. These changes cla rify the differences between oil and gas wells, but now expressly exclude emissions data from wells co

- producing hydrocarbon liquids and natural gas that do not meet the definition of “gas well.” This proposed clarification to the definition of “gas well” underscores the need for EPA to require reporting of completion emissions from oil wells that co

- produce natural gas. We previously urged the Agency to remedy this issue in our March 2013 petition, 24 and recent studies have shown that co

- producing wells ar e significant sources of GHG emissions. 25 Moreover, on April 15th, EPA released a white paper titled Hydraulically Fractured Oil Well Completions and Associated Gas during Ongoing Production. 26 This paper summarizes available methane and VOC emissions data from hydraulically fractured oil wells and notes that additional information could be helpful in characterizing emissions from these sources. The paper further notes that effective approaches are available to mitigate these emissions, and requests comment from both a peer review panel and the public on a variety of emissions

- related issues at hydraulically fractured oil wells. Subpart W could provide helpful information on this important source of emissions. Therefore, we respectfully reiterate our request that EPA undertake a rulemaking to clarify that oil wells venting GHG emissions during well completions or workovers with hydraulic fracturing must also report emissions under Subpart W.
Footnotes:

24 Clean Air Task Force et al., Petition for Rulemaking a nd Guidance Ensuring Comprehensive Coverage of Methane Sources Under Subpart W of the Greenhouse Gas Reporting Rule

— Petroleum and Natural Gas Systems (Mar. 19, 2013), available at http://www2.epa.gov/sites/production/files/documents/ ghgrp_petition_0.pdf. 25 See, e.g., EDF, Co

- Producing Wells as a Major Source of Methane Emissions: A Review of Recent Analyses (March 2014), available at http://blogs.edf.org/energyexchange/files/2014/03/EDF

- Co

- producing

- Wells

- Whitepaper.pdf.

26 EPA, Oil and Natural Gas Sector Hydraulically Fractured Oil Well Completions and Associated Gas during Ongoing Production 44 (Apr. 2014), available at http://www.epa.gov/airquality/oilandgas/pdfs/ 20140415completions.pdf. Response: The EPA thanks the com menter for their input. The commenter’s suggestion for further revisions to subpart W to address GHG emissions from oil wells venting during well completions and workovers with hydraulic fracturing are beyond the scope of this rulemaking. However, the EPA may consider the commenter’s suggestions in a future rulemaking.

263Commenter Name: D. E. Ortman Commenter Affiliation: Document Control Number: EPA

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- 0070 Comment Excerpt Number: 1
Comment: Despite the millions of dollars spent by Amer ica’s National Gas Alliance and the America Petroleum Institute to convince the American people and Congress that national gas and petroleum is “safe,” recent events, including the 12 felony counts filed against Pacific Gas and Electric involving safety vi olations linked to a 2010 natural gas pipeline explosion that killed eight people in the San Francisco Bay area; ExxonMobil’s March 2013 burst pipeline, which spewed thick Canadian tar sands oil through Mayflower, AR; a February 2014, train derailment in P ennsylvania carrying crude oil from Canada, spilling an estimated 3,000 to 4,000 gallons of oil; the March 2014 collision of a barge carrying 924,000 gallons of thick, tarry fuel oil with another ship in the Houston ship channel; a March 2014 fire at a Wil liams Northwest Pipeline natural gas storage facility in Plymouth, Washington, injuring four workers and leading to the evacuation of about 200 people from nearby homes; the March 2014 BP refinery oil spill on Lake Michigan in Indiana; and an April 2014 na tural gas line explosion near the Williams Energy Oak Grove plant construction site in Marshall County, West Virginia, are just the tip in an extremely long list of petroleum and natural gas explosions, spills, and disasters all across the country. Although all of these petroleum spills and collisions and natural gas explosions and disasters release greenhouse gases, they do not appear to be captured by your revised reporting rule. Therefore, unless covered elsewhere, EPA should amend its proposed ru le to require reporting of petroleum and natural gas emissions of each metric ton released of each GHG from all such petroleum spills and collisions and natural gas explosions and disasters. Response: The EPA thanks the commenter for their input. The comm enter’s suggestion for further revisions to subpart W to address GHG emissions from spills, collisions, explosions, and disasters are beyond the scope of this rulemaking.

Commenter Name: Anonymous Commenter Commenter Affiliation: Document Control Num ber: EPA

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- 0071 Comment Excerpt Number: 1
Comment: For the last 2 centuries there has been no evidence that GHG's have any significant influence over climate. The primary GHG is water vapor but acts more as a climate control element to mo derate and transport heat generated from the sun. Water acts as a moderator and heat distribution element, as well as a supply of water vapor, the later which cycles continuously in and out of the climate control system.

264All other alleged GHGs are not of s ufficient quantity to effect anything on a measurable scale. CO2 is more of an indicator of warming then a cause or contributor. Therefore the EPA has no business of trying to be a GHG climate cop as it can't regulate the climate on any level! Response: T he EPA thanks the commenter for their input. The impact of water vapor on climate change is beyond the scope of this rulemaking.

Commenter Name: Carrie B. Crumpton Commenter Affiliation: CONSOL Energy, Inc. Document Control Number: EPA

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- A1 Comment Excerpt Number: 3
Comment: CONSOL requests that EPA clearly define the difference between workover activities and maintenance activities within the language of the rule. This would help to ensure clarity in the classification of well

- si te activities and consistency within the industry as a whole. Response: The EPA did not propose to revise the definition of “well workovers”. As such, this comment is beyond the scope of this rulemaking. We are not amending the definition of “well workove rs” in this final rule.

Commenter Name: Karin Ritter Commenter Affiliation: American Petroleum Institute (API) Document Control Number: EPA

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- A2 Comment Excerpt Number: 2
Comment: API recommends that language be incorporated into the rule language that will clearly differentiate between workover activities and maintenance activities as provided in API’s proposed definition for well workover. Response: The EPA did not propose to revise the definition of “well workovers”. As such, this comment is beyond the scope of this rulemaking. We are not amending the definition of “well workovers” in this final rule.

265