Karin Foster, Esq . Executive Director IPANM 5805 Mariola Place, NE Albuquerque, NM 87111 Fosterassociates2005@Yahoo.com

June	13,	2014 US	EPA	Office	of	Air	Quality Planning	and	Standards	(OAQPS) Raleigh,	NC By	email: oilandgas.whitepapers@epa.gov Re:	 IPANM	 comments	 to	 OAQPS	 Oil	 and	 Natural	 Gas	 Sector	 Pneumatic	 Devices Whitepaper Dear	Sir	or	Madam;
The	 Independent	Petroleum	Association	of	New	Mexico	 (‘IPANM’)	appreciates	 this opportunity	to	comm ent	to	the EPA	Office	of	Air	Quality	Planning	&	Standards	(hereinafter ‘EPA’)	whitepaper	on	Oil	and	Gas	Sector	Pneumatic	Devices	of	April	2014

. Preliminary	matters: Without	adequate	research	and a n expert understanding	of	 the	issues,	it	would	be unethi cal	 for	 th e	 EPA to	 move	 forward	 with	 promulgating methane	 reductions policy	 or rules	 at this	 time. The whitepapers	 and	 studies	 cited	 therein	 do	 not	 appreciate	 that	 the
issues	 around	 methane	 reductions are complex	 and	 very	 dynamic. In	 fact, since	 the
intr oduction	 of	 the	 First	 Assessment	 Report	 (FAR)	 of	 the	 Intergovernmental	 Panel	 of Climate	 Change	 (IPCC	 1990),	 there	 has	 been vigorous discussion	 about whether global warming	potential	(GWP)	to compar e different	gases	on	a	CO2	equivalent	scale should	beIPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 2 of 16 June	13,	2014 Page 2 of 16

------------------------------------------------------------------ the	a ccepted	methodology	to	understand	the	true	impacts	of	methane

. 1 2 As	recently	as	last month,	MIT	 researchers	 published a	letter,	 titled,	 “ Climate	impacts	of	energy	 technologies depend	on	emissions	timing” in Nature	Climate	Change stating	that	the	sta tic	n ature	of	GWP to	compare	ga ses	with	differing	radiative	efficiencies	and	atmospheric	lifetimes	has	led	to ‘major	 shortcomings’	 in	 understanding	 energy	 technology	 valuations 3

. However,	 i n	 the
urgency to	complete	methane	reductions	regulations	by	 the	end	of	2 016,	 the	Whitehouse has	directed	the	EPA	draft	whitepapers	and convene	peer	review	panels to	give	the	agency a	‘robust	understanding’	of	the	issues.		IPANM	would	contend	that	these	whitepapers	were obviously	rushed,	had	a	limited	and	biased	selection	of	st udies	and	we	question	the	efficacy of	the	peer	review	process.		We	hope	that	the	agency	would	proceed	with	this	process in	a manner	 that allows	 for true	 stakeholder	 involvement	 and	 opportunity	 for	 comment as required	in	the federal Administrative	Procedure s	Act. Finally,	we	would	urge	the	agency	to use	the	resources	and	expertise	available	at	the	New	Mexico	Petroleum	Recovery	Research Center	 to	learn	about	 the	unique	characteristics	of	oil	and	gas	operations	in	 the	San	 Juan and	 Permian	 basins. Within	 the	 PR RC	 is	 the Research	 Partnership	 to	 Secure	 Energy	 for America	 (RPSEA),	 Small	 Producer	 Program which	is	 a public/private	 partnership	 funded by	 the	U.S.	DOE	 through	 the	National	Energy	Technology	Laboratory.	The	Small	Producer Program	aims	 to	develop	and	apply technology	 that	enhances	small	producer	production, and	 thereby	 contributes	 to	 the	 nation’s	 energy	 supply.	 The	 PRRC/New	Mexico	 Tech	 was

1 Shine,K. “ The global warming potential

– the need for an interdisciplinary retrial” Climactic Change Journal, Oct. 2009, vol. 96, issue 4, p. 467

- 472. 2 Even as one of the lead authors of one of the chapters of the first IPCC report, Dr. S hine questions whether using the ‘simple approach’ of global warming potential metrics improperly influenced a ‘major piece of 2 Even as one of the lead authors of one of the chapters of the first IPCC report, Dr. S hine questions whether using the ‘simple approach’ of global warming potential metrics improperly influenced a ‘major piece of environmental legislation’ (Kyoto Protocol) that could impact ‘big investment and policy. ’ 3 Edwards, M. & Trancik, J., “ Climate Change of energy technologies depend on emissions timing” , Nature Clim. Change Letter, May 2014,IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 3 of 16 June	13,	2014 Page 3 of 16

------------------------------------------------------------------ chosen	 to	 lea d	 the	 SP	 program	 because	 of	 their track	 record	 of	 research	 and	 actions	 on behalf	of	small	oil	and	gas	prod ucers,	 for	whose	benefit	our	organization	was	established. IPANM	would	also	be	happy	to	provide	additional	input	to	the	EPA	in	the	development	of policy,	rules	and	regulation	on	methane	reduction	strategies.
Who	is	IPANM: The	Independent	Petroleum	Asso ciation	of	New	Mexico,	IPANM,	represents	several hundred	independent	oil	and	gas	producers	who	live,	work	and	employ	New	Mexicans.		We are	small,	with,	on	average,	25	employees	who	often	wear	multiple	proverbial	hats,	but	we provide	enough	revenue	to	the	S tate	of	New	Mexico	to	support	31%	of	the	General	Fund 4

. We strive	to	be	stewards	of	the	land	in	a	state	where	nearly	41.8%	of	the	land	is	federally owned.		The	Bureau	of	Land	Management	New	Mexico	office	manages	one	of	the	largest	oil and	 gas	 programs	 in the	 agency	 controlling	 13.4	 million	 acres	 of	 public	 lands	 and	 26 million	 subsurface	 acres	 of	 federal	 oil,	 natural	 gas,	 and	 minerals.	 	 There	 are	 currently 30,561	active	wells	on	 federal	lands 5 ranking	New	Mexico	sixth	in	crude	oil	production	in the	nation	i n	2013 6 .	New	Mexico’s	marketed	production	of	natural	gas	accounted	for	4.8% of	U.S.	marketed	 natural	 gas	 production	in	 2012,	 despite	 a	 decline	in	 production	 of	 20% between	 2007	 and	 2012 7

. According	 to	 the	 Office	 of	 Natural	 Resources	 Revenue,	 in	 FY
2013	 th e	 Federal	 Government	 disbursed	 $478,732,193.90	 in	 revenues	 to	 New	 Mexico 8 , which	is	only	48%	of	the	total	royalty	revenues	collected	for	oil	and	gas	operations	on	NM federal	lands.

4 “Fiscal Impacts of Oil and Natural Gas Production in New Mexico: Preliminary report”, New Mexico Tax Research Institute, Jan 2014. 5 http://www.emnrd.state .nm.us/OCD/documents/OCD%20Well%20Statistics03272014.pdf 6 http://www.eia.gov/state/?sid=NM 7 Id. 8 http://statistics.onrr.gov/ReportTool.aspxIPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 4 of 16 June	13,	2014 Page 4 of 16

------------------------------------------------------------------ The	 process	 by	which	 these	whitepapers	were	 developed	was	 flawed	 and	 requi res	more study	and	expert	understanding	of	the	issues. Regulation	in	the	air	quality	arena	is	not	new,	however,	IPANM	would	contend	that the	 process	 by	 which	 the	 Whitehouse,	 through	 the	 EPA	 and	 the	 BLM , is	 seeking	 to implement new	 or	 substantially	 expan ded methane	 reduction	 strategies,	 is	 not	 tenable 9

. Note	 that	 IPANM	 does	 not	 contest	 the	 authority	 of	 the	 EPA	 to	 regulate	 Greenhouse	 Gas
emissions 10 ,	of	which	methane	is	a part	of	those	emissions 11 .		T he	authority	under	the	Clean Air	 Act	 and	 a	 growing	 body	 of case	 law,	 grants	 the	 complex	 balancing	 of	 “national	 and international	 policy	 against	 environmental	 benefit,	 our	 nation’s	 energy	 needs	 and	 the possibility	 of	 economic	 disruption”	 solely	 on	 the	 Environmental	 Protection	 Agency. See , American	Electric	Power	v .	Connecticut ,	131	S.Ct.	2527,	564	U.S.	 ____	,slip	op.	10

- 174	at	13 (2011).		Indeed,	through	out	the American	Electric decision,	the	US	Supreme	Court	justices refer	 to	 the	 EPA	 as	 the	 “experts” 12 in	 greenhouse	 gas	 and	 air	 quality	 matters. In	 the
Administrat ion’s	“2014	Climate	Action	Plan:	Strategy	 to	reduce	methane	emissions 13 ”, the
P resident	 orders	 the	BLM,	 the	EPA,	USDA,	DOE	and	even	international	agencies	 to	 target key	 sources	 including	 landfills,	 coalmines,	 agriculture	 and	 the	 oil	 and	 gas	 sector and to

9 IPANM does contend that the statutory jurisdiction to regulate methane reductions lies exclusively with the EP A and not the BLM which is attempting to regulate methane emissions under the guise of a prevention of waste legal theory. 10 In Massachusetts v. EPA , 549 U. S. 497 (2007), the US Supreme Court held that the Clean Air Act, 42 U. S. C. §7401 et seq., author izes federal regulation of emissions of carbon dioxide and other greenhouse gases, including methane. 11 IPANM does, however, contest the science behind the policy for reducing human caused methane sources. Several of our members pointed out in response t o this exercise that the science of global warming and impacts of human activities have not been settled yet. I n 2012, CH4 accounted for about 9% of all U.S. greenhouse gas emissions from human activities. But water vapor in the atmosphere is responsible for 95 percent ofthe greenhouse effect and CO2 is responsible for 3.6 percent. A study from MIT reported on 5/30/07 said that 97% of all greenhouse gases are naturally occurring, and the remaining 3% are caused by man. So methane is only 3% of the 9%. Insi gnificant

. 12 American Electric Power v. Connecticut , 563 US _____, slip op. at p. 3, 16,17,18 13 March 2014 Climate Change Strategy: Reduction of Methane Emissions, found at http://www.whitehouse.gov/sites/default/files/strategy_to_reduce_methane_emissions _2014

- 03

- 28_final.pdf ,IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 5 of 16 June	13,	2014 Page 5 of 16

------------------------------------------------------------------ pr omulgate	rules	to	reduce	methane	emissions.		The	White	House specifically	directs 14 the BLM	to	propose	updated	standards	to	reduce	venting	and	flaring 15
, and mandated	the	EPA to	draft	white	papers	focusing	on	technical	issues relating	to	methane	emissions	fr om “oil
and	 co

- producing	wells,	liquids	 unloading,	leaks,	 pneumatic	 devices	and	 compressors” to “solicit	 input	 from	 independent	 experts 16 ” (hereinafter	 referred	 to	 as	 the	 EPA	 methane papers) .	 	 The	 EPA	 wa s	 further	 order e d to	 use	 these	 documents	 to	 “solidify its understanding	of	these	potentially	significant	sources	of	methane.” The EPA	methane papers	came	out	 for	peer	review	and	comment	one	month	after the	release	of	the	Whitehouse	report with	only 60	days 17 to	comment on	nearly	300	pages
of	technical	data

. The Whitehouse report also	directed	the	agency	to	convene peer	review panels , which	was	done, but	those	panels	only	consist	of 5	persons	per	panel, and not one single	 small	 independent was included	 o n	 any	 panel

. It	 is	 interesting	 to	 note	 that	 the
Environ mental	 Defense	 Fund,	 however,	 was	included	 on	 every	 panel th ereby	 giving	 that group	a	significant	voice	in	this	process

. From a	 detailed	 review	 of	 the EPA	methane	 papers , it	is	 obvious that	 the	 authors

w ere	 clearly	 limited,	 probably	 due	 to	 time	 constrai nts,	 to	 a	 small subset of	 studies	 that were	 often	 out	 of	 date ,	 had	 poor	 sampling	 criteria, had wildly	 inaccurate	 extrapolation
factors or	 cite	 to	 each	 other	 as	 ‘science’

. Of	 the	 few	 studies	 the	 EPA	 relied	 upon,	 every

14 President’s Methane Reduction Strategy, page 2, 9

. 15 The BLM Venting and Flaring public outreach sessions were conducted in North Dakota, New Mexico and Washington DC. IPANM has submitted substantive comments to the BLM on their M ay 2014 Venting & Flaring proposal and would urge both the BLM and this agency to include IPANM, PRRC or RPSEA (see discussion above) in future stakeholder discussions. 16 Id. at 8 par. 2. 17 60 days to read and digest nearly 300 pages of technical inform ation was very difficult. To require industry to commission, prepare and present data to augment the very weak studies relied upon by the EPA was impossible. In addition, the timeframe set did not avail IPANM the ability to structure studies with the New Mexico Petroleum Recovery Research Center or RPSEA who are the entities often commissioned for such work.IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 6 of 16 June	13,	2014 Page 6 of 16

------------------------------------------------------------------ whitepaper referenced a	 study	 commissio ned	 by	 the	 Env ironmental	 Defense	 Fund that reviewed	only	22	sources	of	emissions

. IPANM	strongly	contests	the	use	of	this	paper	as the	 assumptions	 used	 are	 wildly	 inaccurate.	 	 First,	 t he	 average	 $4mcf	 value	 is	 high, particularly	for	smaller	operators	who received	much	less	on	average	during	most	of	2012
and	 2013 18 .	 	 Second,	 the	 base	 assumption	 that	 the	 cost	 of	 flaring	 is	 only	 $ 3523	 per	 well ignores	the	true	costs	which,	by	IPANM	member	review, were well in	excess	of	$10,000	per
well because	 of	 the equipmen t	 rental,	 mileage,	 time and	 personnel	 time	 to	 operate	 the equipment.			As	noted	earlier	in	this	comment,	the	small	producer	has	significantly	different economics	 than	 major	 companies	 who	 employ	 personnel	 versus	 hiring	 consultants	 or
contractors	at	market	r ate	to	conduct	a	test	or an	emergency	procedure	such	as	a	flare	or venting	 during	 liquids	 offloading.	 	 The	 misuse	 of	 the	 cost	 figures	 which ICF	 then extrapolated	 to	 estimate	 savings	 on	 a	 nationwide	 basis	 renders	 the	 EDF	 study	 close	 to meaningless	 as	 a	 foun dation	 for	 a	 Whitehouse	 methane	 reduction	 strategy. Clearly, the
manner	 in	 which	 the	 EPA researched	 the	 is sues	 raised	 in	 the	 whitepapers	 wa s	 nothing more	 than	 a	 ‘data	 dump’	 that	 c ould not	 be	 considered an	 adequate	 learning	 process	 to establish	 expertise	 o n	 these	 very	 complex	 matters

. IPANM	 contends	 that	 based	 on	 the inadequate	 information	 reviewed , that	 the	 EPA	 does	 not	 have	 any	 sort	 of	 a	 ‘robust understanding 19 ’ of	 these	 sources	 of	 methane	 thus,	 moving	 forward	 with	 policy	 or	 rule promulgation	is	premature at	this	time

.

18 http://gotech.nmt.edu/gotech/Marketplace/year_prices.aspx?year=2013 19 In the President’s Climate report ordering EPA to complete the whitepapers, the Whitehouse assumes that completion of the papers would result in ‘robust technical understanding’ of the issues. IPANM contends that in every instance that the studies used and the lack of data does not give EPA regulators the required understanding o f the issues to establish policy.IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 7 of 16 June	13,	2014 Page 7 of 16

------------------------------------------------------------------ In	addition,	 IPANM	would	 urge	 the	 EPA	 to	 review and	 completely	 understand the information included	 in	 the	 National	 emissions	 inventory	 and	 information submitted pursuant	 to	 the	recently	promulgated	NSPS	SubPart	OOOO	amendments 20 .		This	data will provide	a	large amount	of	information	about emissions	at	oil	and	natural	gas	facilities but experts	 who	 understand	 industry must study	 and	 understand	 the	 information	 prior	 to establishing	policy

. 21 NSPS	SubPart	OOOO requires	 federal	air	 standards	 fo r	new	natural gas	 wells	 that	 are	 hydraulically	 fractured,	 along	 with	 requirements	 for	 several	 other sources	 of	 volatile	 organic	 compound	 (VOC)	 emissions	 from	 new	 storage	 vessels,	 newly installed	compressors,	pneumatic	controllers	and	equipment	leaks	at	nat ural	gas	facilities. Although	 the	 New	 Source	 Performance	 Standards	 directly	 regulate	 VOC	 emissions, in	 a Government	Accounting	Office	report	issued	May	16,	2014, the	EPA	reports	that	the	control require ments	 of	 NSPS	 SubPart	 OOOO substantially	 reduce s metha ne	 emissions 22

. C oncurrent	with	the	NSPS, in	April	2012,	EPA published	final	National	Emission	Standards for	 Hazardous	 Air	 Pollutants,	 updating	 its	 air	 toxics	 standards	 for	 oil	 and	 natural	 gas 23

. These	standards	cover	hazardous	air	pollutants	emitted	from	g lycol	dehydrators

— used	to remove	 water	 from	 gas

— and	 storage	 vessels,	 and	 equipment	 leaks	 at	 natural	 gas processing	 plants. Use	 of	actual	measurement	 from	locations	is	 obviously	 better	 towards

20 U.S. EPA, Oil and Natural Gas Sector: New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants Reviews Final Rule, 77 Fed .Reg. 49490 (Aug. 16, 2012) (codified at 40 C.F.R. Parts 60 a nd 63). 21 IPANM would urge the reviewers to look at the UT study that clearly explains differences in modeling based numbers used in the National Emissions Inventory versus actual measurements on location. We would caution against exclusive use of this s tudy, however, since the measurements used were from shale formations only. See, Proceeding of the National Academy of Sciences of the United States of America (PNAS). 2013. Measurement of Methane Emissions at Natural Gas Production Sites in the United St ates. August 19, 2013. Available at http://www.pnas.org/content/early/2013/09/10/1304880110.abstract.. 22 GAO

- 14

- 238; Oil and Gas, Updated Guidance, Increased Coordination, and Comprehensive Data Could Improve BLM's Management and Oversight, page 23 23 77 Fe d. Reg. 49490 (Aug. 16, 2012) (codified at 40 C.F.R. Parts 60 and 63).IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 8 of 16 June	13,	2014 Page 8 of 16

------------------------------------------------------------------ building	an	understanding	of	the	issue	of	methane	emissions,	whi ch	is	what	we	believe	the agency	is	attempting	with	 the	recent	implementation	of	 the	NSPS	regulations.		We	would urge	 the	 EPA	 not	 to	 rush	 to	 creating	 regulations	 for	 all	 new	 and	 existing	 oil	 and	 gas locations	 to	 reduce	 methane	 emissions	 without	 a	 solid	 und erstanding	 of	 the	 actual impacts 24 of	methane	emissions	on	human	health	and	the	environment	or	the	actual	levels emitted	from	all	types	of	oil	and	gas	sources.
Specific	Comments BY	IPANM	Members to	April	2014	Whitepaper,	“ Oil	and	Natural	Gas Sector Compr essors ” Preliminary	comment: If	the	States	share	responsibility	for	air	quality,	any	regulation	or	permitting	should be	at	the	State	level.		Since	flaring	is	a	short

- term	event,	until	infrastructure	is	built, permitting	should	be	simple	and	dovetail	with existing	rules. The	summary	conclusion	in the	paper	that	centrifugal	compressors	with	dry	seals	are	preferable	for	industry	to	use	is premature.		Additional	study	is	needed	that	does	not	include	complete	reliance	on	a	sales pitch	from	one	salesman	or	one gadget	manufacturer	as	is	cited	on	page	34	of	the	report 25

. Page	4	&	5: The re	 is	 no differentiation	 or	 consideration	 for	 single	 acting reciprocating	 compressor	 cylinders. It appears	 that	 they	 are	 assuming	 all	 compressor cylinders	are	double	acting,	and	th ey	are	not.

24 Edwards, M. & Trancik, J., “ Climate Change of energy technologies depend on emissions timing” , Nature Clim. Change Letter, May 2014. T he actual impact of methane from different energ y sources is substantially different than previously believed using the very simplistic GWP modeling. The MIT researchers advocate the use of dynamic modeling that better accounts for the differing radiative efficiencies and atomospheric lifetimes of diffe rent gases. In essence, the comparison of gases must be dependent on the timing of the emissions. The researchers note that while it might be in vogue to tout the disasterous health effects of emissions from coal

fired plants as a policy determination to support natural gas plants, three decades from now, the emissions advantages of natural gas as compared to coal would be half of the levels claimed in the GWP modeling. 25 REM Technology sales data is cited in this report as having a VRU that can reduce o ver 99% of VOC or methane emissions. Is questionable at best and should not be considered ‘science’. IPANM would urge this agency to use the resources of the NM Petrol eum Research Recover y Center to study these technologies.IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 9 of 16 June	13,	2014 Page 9 of 16

------------------------------------------------------------------ Page	8: Why	is	 the	one	and	only	 “Major	Source	of	 Information”	 that	was	put together	by	somebody	with	some	industry	knowledge	only	used	for	well	count?		The		study by	 the	 API/ANGA	 is	 the	 only	 study	 that	 did	 not	 have	 Environmental	 Protection Agen cy/Defense	Fund/Protection	Industry	influence,	and	none	of	its	emissions	calculations
were	used. Section	3.1	GRI/EPA	study	summary: The	 sample	 size	 used	 for	 t his	 study	 is incredibly	small,	only	12	sites. According	to	Table	3

- 10,	note	f,	this	study	“d oes	not	report any	centrifugal	compressors	in	the	production	or	gathering	boosting	sectors,	therefore	no emissions	data	were	published	for	these	two	sectors”.		In	addition,	this	study	was	done	in 1996,	 the	 year	 Google	 was	 formed	 as	 a	 company.	 	 Using	 this	 s tudy	 as	 a	 foundation	 for further	study	ignores	changes	in	compressor	technology	that	can	not	be	ignored.		Further, there	are	several	assumptions	in	 the	GRI	study	 that	was	incorrect,		 the	9.48	SCF/hr	rates assumes	4	cylinders/compressor	with	the	engines	ope rating	and	pressurinzed	79%	of	the time	 for	 gathering	 and	 boosting	 stations	 while	 for	 the	 production	 phase	 this	 report assumed	 the	 compressor	 would	 be	 operating	 and	 pressurized	 100%	 of	 the	 time.	 	 These assumptions	 are	incorrect	 and	impact	 the	 overall	 extra polated	 figures	 of	 emissions	 from
compressors. Moreover,	 this	 GRI study	 gives	 no	 distinction	 between	 sizes	 of	 compressors	 other than	by	what	sector	of	the	industry	they	are	in

– by	no	means	representative	of	the	sizes	of compressors	 used. Each sector	 has its	 own	 emissions	 factors	 and	 they	 are	 clearly representative	of	the	relative	amount	of	gas	that	each	sector	moves,	but	one	factor	can not be	 representative	 of every compressor	 in	 that	 sector. According	 to	 this	 1996	 study, approximately 218	 MMCFD is lost to	 compressor	 seals across	 all	 sectors while	 only	 1.5IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 10 of 16 June	13,	2014 Page 10 of 16

------------------------------------------------------------------ MMCFD	is	attributable	to	the	production	segment.	In	addition,	in	the	GRI	study	there	is	no mention	whatsoever	 of	compressor	stages.		The	majority	 of	compressors	are	multi

- stage, especially	when	 talking about	reciprocating	compressors	in	 transmission,	processing,	and probably	storage	as	well.		Each	stage	has	a	different	suction	and	discharge	pressure,	which are	 the	driving	 forces	behind	seal	leaks.		 If	measurements	were	 taken	on	a	3 rd stage	on	a 2000hp	 re ciprocating	 engine	 that	 emissions	 figure	 is	 completely	 different	 than	 the emission	 factor	 from	 the	 1 st stage	 seal	 on	 a	 500hp	 compressor.	 	 The	 point	 at	 which	 the measurements	are	taken	is	important	but	not	addressed

– lumping	all	the	figures	into	one

secto r,	in	this	case	the	transmissions	sector,	is	clearly	not	representative	of	the	emissions levels	which	is	a	major	failure	of	this	GRI	study. Section	3.2	URS/UT	study	for	EPA: The	 sampl e	 size	 seems	 small	 from	 this study as	well.	 	My	 biggest	issue	with	 this study	is	 the	lack	 of	information	 that	 EPA	gives about	it,	and	incredibly	large		emission	 factors	 for	each	segment	(many	 times	larger	 than the	 previous	 study	 in	 all	 segments).	 	 Their	 sample	 details	 (page	 14)	 reveal	 a	 lot	 to	 me though

– 72%	 of	 the	 reciproca ting	 compressors	 they	 sampled	 were	 at	 transmission stations.		Transmission	stations	will	have	the	l argest	compressors	in	all	of	industry .		They operate	with	the	largest	horsepower,	and	at	the	highest	press ures	because	they	move	the
gas from	 the	 gathering	 s ystems	 in	 the	 field	 to	 one	 pipeline,	 so	 large	 compressors	 are needed	to	move	the	volume	in	the	pipe. Naturally,	given	the	high	discharge	pressures	and huge	 volumes	 of	 gas	 being	 moved	 every	 day,	 these	 machines	 wi ll	 have	 the	 largest seal leakage.		This	pape r	specifies	that	the	transmission	and	gathering	are	broken	out,	but	their sample	sizes	in	the	chart	do	not	match	what	they	specify	at	the	top	of	page	14.		Also,	again there	is no	mention	of	stages.IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 11 of 16 June	13,	2014 Page 11 of 16

------------------------------------------------------------------ 3.3	GHG	Reporting	Program The	data	sources	used	 for	 this study	came	 from	reported	emissions	subsequent	 to the	 G reenhouse	 Gas	 Reporting	 program	 that	 requires	 facilities	 with	 25,000	 metric	 tons carbon	 dioxide	 equivalent	 to	 report.	 	 The	 reports	 allowed	 for	 direct	 measurement, engineering	calculations	or	emission	fa ctors	derived	from	direct	measurement	that	in	some circumstances	allowed	 for	BAMM	 or	 ‘best	available	monitoring	methods’.	 	 The	emissions calculations	 in	 this	 report	 used	 different	 calculations	 methods	 per	 industry	 segment, making	comparison	difficult.		Emi ssions	 from	compressors	onshore	were	calculated	using an	 emissions	 factor	 rather	 than	 direct	 measurement	 that	 was	 used	 in	 other	 industry segments. However,	 it	 is	 interesting	 to	 review	 the results of	 the	 Greenhousegas	 reporting
program are	as	follows:
GHG Processing	Sector	=	10%	lower	than	the	GRI/EPA	study GHG	Transmission	Sector	=	44%	lower	than	the	GRI/EPA	study GHG	Storage	Sector	=	64%	lower	than	the	GRI/EPA	study Several	 IPANM	 members	 felt	 that th e	 approach	 of	 using	 actual	 reported	 numbers from	 a	 larg e	 dataset	 provided	 by	 industry,	 albeit	 subsequent	 to	 regulation, is the	 better approach .	 	 There	 was	 concern	 however,	 and	 significant	 discussion	 that	 the	 emissions factors	 used	 to	 calculate	 the	 levels	 from	 the	 production	 sector	 was	 based	 in	 an	 inflated
emis sions	factor. 3.4	Inventory	of	US	GHG	Emissions	and	Sinks This	inventory	compiles	numbers	based	on	the	GRI	Study	and	submits	them	to	the
UN. Given	 the	 inadequate	 numbers	 of	 the	 GRI	 study	 any	 additional	 work	 based	 on	 thatIPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 12 of 16 June	13,	2014 Page 12 of 16

------------------------------------------------------------------ inappropriate	 foundation	 would render	 subsequent	 studies	 irrelevant.	 	 We	 would	 again point	 to	 the	 table	 for	 the	GRI	werein	 they	admit	 that	no	emissions	data	was	available	 for the	production	sector. 3.5	Development	of	NSPS	for	O&G	Production Again,	this	study	is fundamentally	flawed,	be cause	they	base	all	of	their	calculations on	the	GRI	study,	which	does	not	take	into	account	compression	stages. Moreover,	except for	gathering	and	boosting	sites,	only	5	sites	were	used	 to	develop	emissions	levels.		This report	also	uses	incorrect	gas	com position	for	‘methane

- to
- pollution	ratios’	this	makes	the incorrect	assumption	that	there	is	a	‘one

- size	fits	all’	composition	for	every	gas	stream	from every	 basin	 in	 every	 state.	 	 A	 pressurized	 rate	 of	 100%	 in	 the	 production	 sector	 is	 also incorrectly	as sumed	.

3.6	API/ANGA	Characterizing	Pivotal	Methane	Emissions	from	O&G	Sector
The	EPA discounts API’s	study as	only a	supplement to	EPA’s	data	on	the	prevalence of	wet	versus	dry	seal	compressors	in	the	industry.		The	EPA	concludes	that	these	figures

nee d	 further	 refinement	 and	 therefore	 are	 not	 considered	 here. However,	 this	 study included	 data	 from	 20	 companies	 covering	 over	 90,000	 gas	 wells. The	 authors	 of	 this report	assert	that	the	EPA’s	current	ratio	of	80%	wet	seal	and	20%	dry	seal	overestimated the	emissions	from	the	wet	seal	compressors. 3.7	EDF/ICF	economic	analysis	of	methane	reduction	opportunities IPANM	 members	 question	 the	 validity	 of	 economic	 figures	 coming	 from	 the Environmental	 Defense	 Fund	 as	 the	 basis	 of	 this	 report.	 	 Moreover,	 this study	 projects estimated	growth	of	methane	emissions	by	looking	at	22	sites.		As	noted	above,	 the	basicIPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 13 of 16 June	13,	2014 Page 13 of 16

------------------------------------------------------------------ assumptions	of	this	study	are	extremely	flawed	and,	in	particular	misstate	the	cost	factors that	small	producers	must	 face	with	 the	proposed	methane	mit igation	strategies	outlined in	this	report.
3.7.1.1

– Gathering	and	Boosting	Segment The	fact	that	data	is	split	between	large	and	small	compressors	at	a	line	of	1600hp	is beyond	absurd.		There	is	nothing	about	the	operating	parameters	that	affect	seal	e missions between	 a	 100hp	 machine	 and	 a	 1600	 hp	 machine	 that	 can	 be	 generalized	 or	 averaged across	 the	board or	is remotely	accurate	or	representative	of	what is	actually	used	in	 the field. The	increase	of	166%	over	 the	incredibly	high	GRI	study	 from	1996 in	 “estimated”
methane	emissions now	sited	in	this	report	is	a	telling	indicator	as	to	the	accuracy	of	these numbers.
3.7.1.3	Gas	Transmission It	 appears	 here	 that	 they	 are	 estimating	 the	 number	 of	 transmission	 compressors based	 strictly	 on	 pipeline	 mile s.	 	 I PANM	 recommends	 a	 better	 method	 of	 calculation	 of compressions	for	transmission	would	be	to	look	at	actual	data	from	permits.

Section	4.0	Mitigation
I PANM	 members	 would	 note	 that	 the	 mitigation	 techniques	 considered	 need	 to balance	economics	with	env ironmental	benefits.		Retrofiting	existing	locations	may	not	be economic	for	marginal	producing	wells	therefore new	designs	for	seals	in	new	machine	rod packing	 and	 capture/redirect	 technology	 would	 be preferable	 for	 industry .	 	 Enhanced maintenance	is	a	po ssibility	but	includes	increases	in	station	blowdown	and	flaring.IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 14 of 16 June	13,	2014 Page 14 of 16

------------------------------------------------------------------ Charge	Questions

1. Please comment on the national estimates of methane emissions and methane emission factors for vented compressor emissions presented in this paper. Please comment on the activity data and the methodologies used for calculating emission factors presented in this paper. I	feel	that	the	estimates	are	not	representative.		The	sample	sizes	are	too	small,	and the	assumptions	taken	to	cover	all	compressors	are	too	simple	(no	me ntion	in	entire	paper of	compression	stages)
2. Did this paper appropriately characterize the different studies and data sources that quantify vented emissions from compressors in the oil and gas sector? Yes,	 it	 did	 characterize	 the	 studies	 well	 but	 the	 stud ies	 had	 problems	 with	 data quality	and	inappropriate	extrapolation. 3. Did this paper capture the full range of technologies available to reduce vented emissions from reciprocating compressors and wet seal centrifugal compressors at oil and gas facilities ? In particular, are there other options for reducing emissions at existing reciprocating or centrifugal compressors? For example, the EPA is aware of “low emissions packing” for reciprocating compressors but has no detailed information on this technology.
Yes.
4. Did this paper appropriately characterize the emissions reductions achievable from the emissions mitigation technologies discussed for reciprocating compressors and wet seal centrifugal compressors? Yes. 5. Did this paper appropriately char acterize the capital and operating costs for the technologies discussed for reduction of vented emissions from reciprocating compressors and wet seal centrifugal compressors?
Yes. 6. If there are emissions mitigation options for reciprocating and centri fugal compressors that were not discussed in this paper, please comment on the pros and cons of those options. Please discuss the efficacy, cost and feasibly for both new and existing compressors. Not aware of any others. 7. Are there technical limitati ons that make the replacement of wet seals with dry seals impractical at certain existing centrifugal compressors?IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 15 of 16 June	13,	2014 Page 15 of 16

------------------------------------------------------------------ 8. Are there technical reasons why an operator would use a wet seal centrifugal compressor without a gas recovery system? 9. Are there tech nical limitations that make the installation of gas capture systems at certain reciprocating compressors impractical? Gas capture	 is	 probably	 the	 best	 option,	 however	 it	 needs	 to	 be	 supplied	 by compressor	packagers	as	an	option. Ther e	will	be	small	producer	issues	with	 this	option whose	marketing	contracts	etc.	may	need	to	be	redrafted.		ONRR	may	also	b e	interested. 10. Please comment on the prevalence of the different emission mitigation options in the field. Other	 than	 in	 cylinder	 combustion	 efforts	 ( AFR’s)	 and	 catalysts, many	 small upstream producers do	 not	 deal	 with emission	 mitigation	 technologies	 like	 rod	 packing capture	technologies. 11. Given the substantial benefits of dr y seal systems (e.g., lower emissions, less maintenance, and higher efficiency), are you aware of situations where new wet seal centrifugal compressors are being installed in the field? If so, are there specific applications that require wet seal compresso rs? 12. Are there ongoing or planned studies that will substantially improve the current understanding of vented VOC and methane emissions from reciprocating and centrifugal compressors and available techniques for increased product recovery and emissions reductions? IPANM	 would	 urge	 this	 agency	 to	 use	 the	 resources	 at	 New	 Mexico	 Petroleum Recovery Research Center	to	commission	additional	studies. IPANM	 thanks	 the	 EPA	 for	 the	 opportunity	 to	 comment	 on	 the	Oil	 and	 gas	 Sector Hydraulically	 Fractured	 Oil	 Well	 Completions	 and	 Associated	 Gas	 during	 Ongoing Operations	 whitepaper.	 We	 would	 be	 interested	 in	 participating	 in	 any stakeholder/taskforce/ peer	 review	groups	 convened	 for	 the	 purpose	 of	addressing	 these policy	proposals.		We	look	forward	to	providing	additional	comments	as	the	agency	drafts of	 these	 proposed	 regulations	 materialize.	 	 Please	 feel	 free	 to	 contact	 me	 at Karin@ipanm.org or	at	(505)	238

- 8385	if	you	have	any	questions	regarding	the	issues.IPAN M	Comments: Compressors Whitepaper June	13,	2014 Page 16 of 16 June	13,	2014 Page 16 of 16

------------------------------------------------------------------ Respectfully	submitted,
INDEPENDENT	PETROLEUM	ASSOCITION	OF	NEW	MEXICO

______________________________________________ By:	Karin	V.	Foster,	esq. Executi ve	Director