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	comment	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	an expert	understanding	of	 the	issues,	it	would	be	

unethical	 for	 the	 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	

introduction	 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 compare different	gases	on	a	CO2	equivalent	scale should	be	
IPANM	Comments:	Compressors Whitepaper

June	13,	2014

Page 2 of 16

June	13,	2014

Page 2 of 16

------------------------------------------------------------------

the	accepted	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	static	nature	of	GWP	

to	compare	gases	with	differing	radiative	efficiencies	and	atmospheric	lifetimes	has	led	to	

‘major	 shortcomings’	 in	 understanding	 energy	 technology	 valuations3. However,	 in	 the	

urgency to	complete	methane	reductions	regulations	by	 the	end	of	2016,	 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	studies	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	Procedures	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	 PRRC	 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. Shine 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. Shine 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, 
IPANM	Comments:	Compressors Whitepaper

June	13,	2014

Page 3 of 16

June	13,	2014

Page 3 of 16

------------------------------------------------------------------

chosen	 to	 lead	 the	 SP	 program	 because	 of	 their	track	 record	 of	 research	 and	 actions	 on	

behalf	of	small	oil	and	gas	producers,	 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	Association	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	State	of	New	Mexico	to	support	31%	of	the	General	Fund4.		

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	lands5 ranking	New	Mexico	sixth	in	crude	oil	production	in	

the	nation	in	20136.	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	 20127. According	 to	 the	 Office	 of	 Natural	 Resources	 Revenue,	 in	 FY	

2013	 the	 Federal	 Government	 disbursed	 $478,732,193.90	 in	 revenues	 to	 New	 Mexico8,	

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.aspx
IPANM	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	 requires	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	 expanded	 methane	 reduction	 strategies,	 is	 not	 tenable9.

Note	 that	 IPANM	 does	 not	 contest	 the	 authority	 of	 the	 EPA	 to	 regulate	 Greenhouse	 Gas	

emissions10,	of	which	methane	is	a	part	of	those	emissions11.		The	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	

Administration’s	“2014	Climate	Action	Plan:	Strategy	 to	reduce	methane	emissions13”,	the	

President	 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 EPA 

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., authorizes 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 to this exercise that the science of global warming and impacts 

of human activities have not been settled yet. In 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%. Insignificant. 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,
IPANM	Comments:	Compressors Whitepaper

June	13,	2014

Page 5 of 16

June	13,	2014

Page 5 of 16

------------------------------------------------------------------

promulgate	rules	to	reduce	methane	emissions.		The	White	House	specifically	directs14 the	

BLM	to	propose	updated	standards	to	reduce	venting	and	flaring15, and mandated	the	EPA	

to	draft	white	papers	focusing	on	technical	issues relating	to	methane	emissions	from “oil	

and	 co-producing	wells,	liquids	 unloading,	leaks,	 pneumatic	 devices	and	 compressors”	to	

“solicit	 input	 from	 independent	 experts16” (hereinafter	 referred	 to	 as	 the	 EPA	 methane	

papers).	 	 The	 EPA	 was	 further	 ordered	 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	days17 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	 on	 any	 panel.	 It	 is	 interesting	 to	 note	 that	 the

Environmental	 Defense	 Fund,	 however,	 was	included	 on	 every	 panel thereby	 giving	 that	

group	a	significant	voice	in	this	process.	

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

were	 clearly	 limited,	 probably	 due	 to	 time	 constraints,	 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 May 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 information 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. 
IPANM	Comments:	Compressors Whitepaper

June	13,	2014

Page 6 of 16

June	13,	2014

Page 6 of 16

------------------------------------------------------------------

whitepaper referenced a	 study	 commissioned	 by	 the	 Environmental	 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,	 the	 average	 $4mcf	 value	 is	 high,	

particularly	for	smaller	operators	who received	much	less	on	average	during	most	of	2012	

and	 201318.	 	 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 equipment	 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	rate	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	 foundation	 for	 a	 Whitehouse	 methane	 reduction	 strategy.	 	 Clearly,	the	

manner	 in	 which	 the	 EPA researched	 the	 issues	 raised	 in	 the	 whitepapers	 was	 nothing	

more	 than	 a	 ‘data	 dump’	 that	 could	 not	 be	 considered	 an	 adequate	 learning	 process	 to	

establish	 expertise	 on	 these	 very	 complex	 matters.	 IPANM	 contends	 that	 based	 on	 the	

inadequate	 information	 reviewed, that	 the	 EPA	 does	 not	 have	 any	 sort	 of	 a	 ‘robust	

understanding19’ 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 of the issues to establish policy. 
IPANM	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	amendments20.		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	 for	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	natural	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	

requirements	 of	 NSPS	 SubPart	 OOOO	 substantially	 reduces methane	 emissions 22 .	

Concurrent	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	 gas23.	

These	standards	cover	hazardous	air	pollutants	emitted	from	glycol	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 and 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 study, 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 States. 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 Fed. Reg. 49490 (Aug. 16, 2012) (codified at 40 C.F.R. Parts 60 and 63).
IPANM	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,	which	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	 understanding	 of	 the	 actual	

impacts24 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	Compressors”

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	report25.

Page	4	&	5: There	 is	 no differentiation	 or	 consideration	 for	 single	 acting	

reciprocating	 compressor	 cylinders.	 It appears	 that	 they	 are	 assuming	 all	 compressor	

cylinders	are	double	acting,	and	they	are	not.

																																																							 24 Edwards, M. & Trancik, J., “Climate Change of energy technologies depend on emissions timing”, Nature Clim. 

Change Letter, May 2014. The actual impact of methane from different energy 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 different 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 coalfired 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 over 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 Petroleum Research Recovery Center to study these technologies. 
IPANM	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	

Agency/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	 this	 study	 is	

incredibly	small,	only	12	sites. According	to	Table	3-10,	note	f,	this	study	“does	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	 study	 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	operating	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	 extrapolated	 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	 1.5	
IPANM	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	3rd stage	on	a	

2000hp	 reciprocating	 engine	 that	 emissions	 figure	 is	 completely	 different	 than	 the		

emission	 factor	 from	 the	 1st 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	

sector,	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	 sample	 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	 reciprocating	 compressors	 they	 sampled	 were	 at	 transmission	

stations.		Transmission	stations	will	have	the	largest	compressors	in	all	of	industry.		They	

operate	with	the	largest	horsepower,	and	at	the	highest	pressures	because	they	move	the	

gas from	 the	 gathering	 systems	 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	 will	 have	 the	 largest	 seal	

leakage.		This	paper	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.
IPANM	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	 Greenhouse	 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	factors	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.		Emissions	 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 the	 approach	 of	 using	 actual	 reported	 numbers	

from	 a	 large	 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	

emissions	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	 that	
IPANM	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,	because	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	composition	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	assumed	.	

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	

need	 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	basic	
IPANM	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	mitigation	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	emissions	

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	 miles.	 	 IPANM	 recommends	 a	 better	 method	 of	 calculation	 of	

compressions	for	transmission	would	be	to	look	at	actual	data	from	permits.

Section	4.0	Mitigation

IPANM	 members	 would	 note	 that	 the	 mitigation	 techniques	 considered	 need	 to	

balance	economics	with	environmental	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	possibility	but	includes	increases	in	station	blowdown	and	flaring.		
IPANM	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	mention	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	 studies	 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 characterize 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 centrifugal 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 limitations that make the replacement of wet seals with dry seals impractical at 

certain existing centrifugal compressors? 
IPANM	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 technical 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.		There	will	be	small	producer	issues	with	 this	option	

whose	marketing	contracts	etc.	may	need	to	be	redrafted.		ONRR	may	also	be	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 dry 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 compressors? 

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.	
IPANM	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.	

Executive	Director