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U.S. Environmental Protection Agency

oilandgas.whitepapers@epa.gov

Re: Comments on the U.S. Environmental Protection Agency’s White Papers Regarding

Methane and Volatile Organic Compound Emissions in the Oil and Natural Gas Sector

To Whom It May Concern:

Kinder Morgan Energy Partners, L.P. (Kinder Morgan) appreciates the opportunity to

comment on the U.S. Environmental Protection Agency’s (EPA) technical white papers regarding

potential sources of methane and volatile organic compound (VOC) emissions in the oil and natural

gas sector (the “White Papers”). Kinder Morgan strongly encourages EPA to evaluate all the

information received both from peer reviewers and the public, as well as other existing and

anticipated regulatory requirements, in its evaluation of the need for and potential mechanisms for

reducing methane emissions from the oil and gas sector, particularly in the transmission and storage

sector.

I. INTRODUCTION

On April 15, 2014, EPA released for external peer review and public comment five technical

White Papers on potential sources of methane and VOC emissions in the oil and gas sector. EPA

focuses on technical issues regarding the scope of emissions and available mitigation techniques

that target reductions of methane and VOCs from the oil and gas sector. EPA proposes to use the

White Papers, along with input EPA receives from the peer reviewers and the public, to determine

how and whether to best pursue additional methane reductions from the sources in the oil and gas

sector. Specifically, the White Papers address emissions from: compressors; completions and

ongoing production of hydraulically fractured oil wells; leaks; pneumatics devices; and liquids

unloading. See Oil and Natural Gas Sector Compressors, Report for Oil and Natural Gas Sector

Compressors, Review Panel, April 2014 (“Compressor White Paper”); Oil and Natural Gas Sector

Leaks, Report for Oil and Natural Gas Leaks, Review Panel, April 2014 (“Leaks White Paper”); and

Oil and Natural Gas Sector Pneumatic Devices, Report for Oil and Natural Gas Sector Pneumatic

Devices, Review Panel, April 2014 (“Pneumatics White Paper”). EPA has requested comments and

technical information by June 16, 2014. Kinder Morgan timely submits these comments in response

to EPA’s White Papers regarding compressors, leaks, and pneumatic devices. Kinder Morgan

further incorporates the comments of several trade associations by reference, including: American

Petroleum Institute (API) and Interstate Natural Gas Association of America (INGAA). Kinder

Morgan further attaches responses to EPA’s charge questions in Exhibit A, attached and

incorporated hereto.
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II. EXECUTIVE SUMMARY

Kinder Morgan appreciates this opportunity to comment on the EPA White Papers. As a

leading energy, transportation, and storage company in North America, Kinder Morgan focuses its

comments on those White Papers applicable to the transmission and storage sector: the

Compressor White Paper, the Pneumatics White Paper, and the Leaks White Paper. Kinder Morgan

has significant experience in assessment of greenhouse gas (GHG) emissions and regulatory

regimes regarding compressors, pneumatics, and leaks through its participation in the GHG

reporting program, EPA’s Natural Gas STAR program, and regulation under New Source

Performance Standards (Sections OOOO and KKK). In Kinder Morgan’s experience, the vast

majority of methane emissions come from either: (1) blowdowns of pipeline associated with

maintenance or pipe replacement; or (2) a small number of components, typically associated with

compressors. Prior to developing regulations or other mechanisms to reduce methane emissions

from the transmission and storage sector, Kinder Morgan strongly urges EPA to consider the

following:

 EPA should use data from the GHG reporting program to establish baseline emissions rates

for the transmission and storage sector as the GHG reporting program provides accurate

data regarding emissions from such sources, which are significantly less than what EPA has

represented in their national inventory.

 EPA should coordinate with the Pipeline and Hazardous Materials Safety Administration

(PHMSA) to address potential reductions in methane emissions that occur as a result of

PHMSA’s current regulations requiring installation of new pipe (with limited exceptions) when

population density changes the class location of the pipe. The methane emissions that result

from blowdowns necessary to upgrade the pipe can be avoided without impacting safety

considerations, and EPA should work with its sister agency to evaluate this readily available

source of methane emission reductions.

 EPA should not proceed with any decisions regarding methane reductions from the

transmission and storage sector until it better understands the emissions from the various

sources and components in the transmission and storage sector. Specifically, EPA should

wait until after the studies and reports referenced in Kinder Morgan’s comments—namely

those being conducted by Colorado State University and Pipeline Research Council

International—have been completed and the findings of those studies and reports reviewed

and understood by EPA. With the additional data collected during the technical review

period on the White Papers, a review of the GHG reporting program data, and the

information from these studies, EPA will have the relevant information to determine those

sources that may be most appropriate for reduction in the transmission and storage sector

(i.e., which sources in fact have the highest methane emissions). Current emissions

information provided by EPA conflicts with the data collected by Kinder Morgan and others,

and thus warrants further review.

 EPA should not proceed with any decision regarding methane reductions from the

transmission and storage sector until it better understands the complex nature of existing

regulations governing entities operating in the transmission and storage sector and

understands the differences between compressors, leaks, and pneumatics in the
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transmission and storage sector as compared to upstream sectors, such as oil and gas

production. Specifically, EPA should coordinate its analysis with the U.S. Department of

Energy (DOE) and should not proceed with any decision regarding methane reductions from

the transmission and storage sector until the DOE has completed its quadrennial review that

will address “downstream” methane opportunities.

 EPA should carefully consider the technical feasibility of many of the proposed mitigation

reduction strategies and again await the results of the Pipeline Research Council

International report prior to identifying available or feasible emissions reduction technologies.

Kinder Morgan does not agree that many of the mitigation technologies, including use of a

vapor recovery unit system to reduce emissions from rod packing or converting wet seals to

dry seals, are either environmentally beneficial or technically or economically feasible.

 EPA should not regulate existing sources, particularly in the transmission and storage sector

based on PHMSA and the Federal Energy Regulatory Commission (FERC) jurisdiction. The

transmission and storage sector raises considerations very different from those in the

exploration and production and processing sectors. Furthermore, the technologies are not

proven for and have not been applied even for new sources within the transmission and

storage sector.

 EPA should re-evaluate its position regarding leak repairs and ease of the repair, particularly

in the transmission and storage sector. In the transmission and storage sector, repair can

require either blowdown of pipeline or blowdown of the compressor piping—an event that

releases methane directly to the atmosphere—frequently in greater quantities than emitted

from any leak requiring repair.

 EPA should not adopt a leak detection and repair program for the transmission and storage

sector. Instead, EPA should either encourage or require (if necessary) operators of

transmission and storage facilities to develop a directed inspection and maintenance

program that addresses several of the white paper topics (i.e., compressors and leaks).

Development of a directed inspection and maintenance program is consistent with EPA’s

own data and that of Kinder Morgan and others that a small number of components account

for the vast majority of emissions. As a result, it is cost-effective and environmentally

beneficial to focus on identifying that small number of components instead of conducting a

full scale leak detection and repair program or a mandatory command and control

requirement.

 EPA should not regulate pneumatic devices in the transmission and storage sector. Data

from Kinder Morgan’s operations indicate that pneumatics account for 1% or less of the total

emissions reportable by Kinder Morgan under the GHG reporting program. These

insignificant sources do not warrant regulation or emissions reductions in the transmission

and storage sector.

Kinder Morgan remains committed as always to working with EPA, industry, and other

stakeholders to identify environmentally beneficial, cost-effective and technologically feasible

mechanisms for reducing emissions from its operations. Kinder Morgan provides more detailed

comments below.
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III. OVERVIEW OF KINDER MORGAN’S OPERATIONS

Kinder Morgan is a leading energy, transportation and storage company in North America.

With approximately 70,000 miles of pipelines and 586 billion cubic feet (Bcf) of storage, Kinder

Morgan is the largest natural gas transporter and largest storage operator in North America. Kinder

Morgan’s pipelines are connected to every important natural gas resource play, including the Eagle

Ford, Marcellus, Utica, Uinta, Haynesville, Fayetteville, Barnett, Mississippi Line and Woodford, that

will play a significant role in meeting the nation’s long-term natural gas supply. Kinder Morgan

serves the major natural gas consuming markets of the entire United States. Key Kinder Morgan

natural gas pipeline assets include Natural Gas Pipeline Company of America (which serves the

high-demand Chicago market); Tennessee Gas Pipeline (which serves New York City and Boston);

Southern Natural Gas (which serves the southeastern United States); and intrastate pipelines in

Texas (Texas is the largest producer and consumer of natural gas in the United States), El Paso

Natural Gas, Mojave Pipeline and Ruby Pipeline that service California markets. Kinder Morgan

also operates gathering systems, several gas processing plants, and two liquefied natural gas (LNG)

terminals.

IV. EPA’S METHANE STRATEGY SHOULD BE COORDINATED WITH THE DEPARTMENT

OF ENERGY

EPA’s methane White Papers were released as part of President Obama’s Climate Action

Plan: Strategy to Reduce Methane Emissions (March 2014) (“Methane Strategy”). With respect to

the oil and natural gas sector, the Methane Strategy identified three planned efforts by agencies

within the Administration: (1) EPA’s technical review through the White Papers; (2) Bureau of Land

Management’s (BLM) proposed venting and flaring regulations; and (3) DOE’s Quadrennial Energy

Review to address “downstream” methane opportunities. Interestingly, EPA’s White Papers—

particularly the Compressor White Paper, Leaks White Paper, and Pneumatics White Paper—

address emissions sources in the downstream natural gas sector. However, at this time, DOE has

not yet completed its quadrennial review. EPA’s White Papers do not address how its technical

review (and any program resulting from that review) correlates with the direction provided to DOE.

Kinder Morgan has significant concern that in the White Papers, EPA appears to treat the

transmission and storage sector as identical to the upstream oil and gas sector. Kinder Morgan

strongly urges EPA to consider the complex nature of the transmission and storage sector of the

natural gas industry; a sector that is not only independent from the upstream oil and gas sector, but

also heavily regulated by DOE through FERC and the Department of Transportation’s PHMSA.

Kinder Morgan and other regulated entities seek certainty regarding regulatory frameworks and

strongly encourage EPA to coordinate its analyses with those other agencies regulating the

transmission and storage sector before proceeding with any regulations or mechanism for achieving

methane reductions from the transmission and storage sector. Finally, Kinder Morgan strongly

urges EPA to refrain from pursuing emissions reductions from sources downstream of natural gas

processing facilities until DOE has completed its review and the necessary coordination can occur.
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V. KINDER MORGAN METHANE EMISSIONS ASSESSMENT AND REDUCTION

EXPERIENCE

Kinder Morgan has significant experience in the assessment of GHG emissions and existing

regulatory regimes regarding compressors and leaks. In fact, Kinder Morgan first began

implementing the GHG reporting program in 2009. This effort has included compliance with the

annual surveys and measurements required by 40 C.F.R. Part 98, Subpart W, for Kinder Morgan’s

onshore natural gas transmission compression, underground natural gas storage, onshore natural

gas processing, and LNG import and export facilities. In fact, Kinder Morgan currently has almost

200 transmission, storage, gas processing, and LNG facilities for which it performs monitoring

annually under Subpart W. Kinder Morgan brings a unique perspective along with experience and

insight to methane emissions in the natural gas sector because it has collectively monitored its 200

facilities subject to Subpart W nearly 600 times over the course of 2011, 2012, and 2013 under

EPA’s Subpart W reporting program, using internal personnel and third-party contractors (200

facilities X 3 years = 600 times). By using operations personnel familiar with the facilities, Kinder

Morgan has been able to more closely identify and understand technical obstacles associated with

GHG emissions reporting. Kinder Morgan’s monitoring of these facilities has included monitoring of

several of the sources under evaluation in the White Papers, including compressors, pneumatic

devices and leaks.

Due to Kinder Morgan’s extensive gas pipeline network and sizable number of facilities

providing natural gas transmission, storage, and processing services on a continuous basis, Kinder

Morgan has a large number of facilities triggering GHG reporting and monitoring. Ultimately, this

has resulted in the collection of thousands of data inputs over the last three (3) years and provides

Kinder Morgan with the unique opportunity to present the EPA with an analysis of our Subpart W

data that we consider a key component in determining a reasonable approach to effectively

achieving methane emissions reductions.

In addition, Kinder Morgan’s pipeline companies have participated in EPA’s Natural Gas

STAR Program since 1993. Kinder Morgan’s natural gas operations have achieved methane

emissions reductions of over 80 Bcf since 1993, with combined reductions in 2011 and 2012 of

approximately 3 Bcf. Kinder Morgan has achieved those reductions by implementing cost-effective

measures to reduce methane releases from its operations and by repairing identified leaks. Various

technologies have been implemented to reduce methane emissions including, but not limited to:

 Implementation of directed inspection and maintenance programs at our compressor stations

and other surface facilities (e.g., meter stations);

 Replacing rod packing systems on some reciprocating compressor engines, in certain

circumstances;

 Replacing high-bleed pneumatics;

 Installing vapor recovery systems on storage tanks;

 Pumping or drawing down sections of pipe prior to conducting maintenance activities;

 Installing full encirclement or composite sleeves for pipeline maintenance to eliminate the

need for pipeline blowdowns; and

 Installing either gas turbines or electric motor driven compression, as appropriate, rather

than installing reciprocating compressor engines.
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Historically, Kinder Morgan’s greatest reductions come from preventing natural gas venting

or “blowdowns” of pipeline sections prior to conducting maintenance activities. Drawing down

pressures with existing compression, using portable compressors to recompress gas into other

pipelines or pipeline sections, and the use of full encirclement or composite sleeves reduces the

amount of natural gas that would otherwise be released into the atmosphere when conducting

maintenance activities (when appropriately applied, considering safety and other concerns). Kinder

Morgan’s own efforts to voluntarily reduce methane emissions demonstrate that strict command and

control regulatory regimes are simply not the best answer for reducing methane emissions from the

oil and natural gas sector, and particularly the transmission and storage sector. Rather, the industry

should seek to identify high-impact, cost-effective mitigation options for the greatest emission

sources. Further information about proposed and preferred approaches are provided below.

VI. NATURE OF THE NATURAL GAS PIPELINE SECTOR

According to EPA, the driving force behind proposed regulations is the dramatic increase

in upstream production in the last several years. Importantly, compressors (such as those in the

transmission and storage sector) have not been increasing in linear relation to upstream

production. Additionally, as new natural gas pipeline infrastructure occurs, the new systems will

be more efficient and have even fewer emissions.

The transmission and storage sector of the natural gas industry proves very complex and

in most circumstances is heavily regulated by DOE through FERC, and the Department of

Transportation through PHMSA, particularly for safety purposes. In fact, PHMSA has

established programs requiring operators to implement fixed gas detection and alarm systems in

each compressor building and to develop procedures for leak surveillance and repair. For

example, under 49 C.F.R. Section 192.613, PHMSA requires that each operator “have a

procedure for continuing surveillance of its facilities to determine and take appropriate action

concerning changes in class location, failures, leakage history, corrosion, substantial changes in

cathodic protection requirements, and other unusual operating and maintenance

conditions.” See 49 C.F.R. § 192.613(a); see also 49 C.F.R. § 192.736 (requiring gas detection

equipment); 49 C.F.R. § 192.703(b)−(c) (“Each segment of pipeline that becomes unsafe must

be replaced, repaired, or removed from service; Hazardous leaks must be repaired promptly.”).

Natural gas pipelines do not own the gas that they transport; rather they function like a toll

road and are paid a transportation fee. Kinder Morgan and other natural gas pipeline companies

compete against one another in a highly competitive market and cannot, contrary to some

misconceptions, automatically pass on regulatory costs to their customers. Even though Kinder

Morgan operates pipelines subject to regulatory oversight by 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 regulatory costs caused by new regulation—cannot be

automatically added to the shipping rate and are instead born by the pipeline company.

Moreover, while interstate natural gas pipelines are regulated by FERC, intrastate

pipelines, gathering systems, and gas plants are not subject to FERC jurisdiction. Each of the

production and consuming markets in the United States is served by multiple pipeline operators.
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Therefore, all Kinder Morgan natural gas pipelines and facilities compete in the marketplace for

services provided to existing and new shippers and customers as well as for new expansion

projects through competitive contract negotiations, regardless of whether they are subject to

FERC regulation or not. Cost competiveness, services provided and service reliability are major

factors in maintaining current customer commitments/contracts and in obtaining new business.

Similar to other industries potentially subject to requirements to reduce methane emissions,

natural gas pipeline companies are also impacted by the competitive marketplace and these

companies have to manage their costs of providing gas transportation services. If these costs

are not properly managed, the companies will not be able to compete in the market place. Thus,

proposed efforts to reduce methane emissions, particularly through a command and control

regulation that may not focus properly on the most efficient and significant sources or that

incorrectly assumes that all costs will be recouped by natural gas savings, causes great concern

to Kinder Morgan.

Importantly, Kinder Morgan operates high pressure pipelines. As a result, Kinder

Morgan does not have the “leak tolerances” that perhaps others operating lower pressure

gathering and utility service lines are allowed. A breech of natural gas pipelines in the

transmission and storage sector can result in a serious event that should be avoided at all costs.

To avoid such an event, Kinder Morgan devotes considerable money, technology, labor, and

other resources, to identify pipeline sections that need to be repaired or replaced, even in the

absence of methane regulations requiring reduction of leaks.

VII. EPA SHOULD NOT REGULATE EXISTING SOURCES

In several places, EPA’s White Papers discuss retrofitting of sources, replacement of

sources, and other statements that suggest that EPA may be considering reduction of methane from

existing sources. As noted elsewhere in these comments, Kinder Morgan recommends a flexible,

company-driven approach to methane reductions and specific to existing sources, strongly urges

EPA not to regulate existing sources at this time. Specific to the transmission and storage sector,

EPA has not yet sought to regulate new sources. As such, regulation of existing sources would be

premature. Furthermore, EPA has not yet regulated the sources at issue (compressors, pneumatics,

and leaks) for GHG or methane emissions. As EPA understands, EPA does not have unfettered

authority to impose nationally-applicable standards of performance on existing sources under

Section 111(d) of the Clean Air Act (CAA). See, e.g. EPA, Proposed Rule, “Emission Guidelines for

Existing Stationary Sources: Electric Utility Generating Units,” at (June 2, 2014) (the “Clean Power

Plan”) (“Under the authority of [CAA] [S]ection 111(d), the EPA is proposing emission guidelines for

states to follow in developing plans to address [GHG] emissions from existing fossil fuel-fired electric

generating units.”) (emphasis added). In fact, Section 111(d) does not directly authorize EPA to

establish standards of performance for existing sources; rather, Section 111(d) directs EPA to

“prescribe regulations which shall establish a procedure similar to that under [CAA Section 110]

under which each State shall submit to [EPA] a plan which . . . establishes standards of

performance” for existing sources within that state. See 42 U.S.C. § 7411(d)(1) (emphasis added);

see also 42 U.S.C. § 7411(d)(1) (EPA’s authority to devise standards of performance for existing

sources is limited to the situation “where a State fails to submit a satisfactory plan.”).

As directed by Section 111(d) of the CAA, in 1975, EPA promulgated regulations to

“establish a procedure” for states to develop standards of performance for existing sources. Under

this statutory and regulatory scheme, EPA bears the burden of providing guidance to states in the
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form of a “guideline document.” See 40 C.F.R. § 60.22 (“Concurrently upon or after proposal of

standards of performance for the control of a designated pollutant from affected facilities, the

Administrator will publish a draft guideline document containing information pertinent to control of the

designated pollutant from designated facilities.”). Specifically, to inform states’ respective plans

under Section 111(d), EPA must provide to the states an emission guideline “that reflects the

application of the best system of emission reduction (considering the cost of such reduction) that has

been adequately demonstrated for designated facilities.” See 40 C.F.R. § 60.22(b)(5) (emphasis

added); see, e.g., the Clean Power Plan, at 15 (proposing a system of GHG emissions reduction

“[b]ased on evidence from programs already being implemented by many states as well as input

received from stakeholders”). In August 2012, EPA published new source performance standard

(NSPS) OOOO, which regulates VOCs at oil and gas sources only, but not methane. See 77 Fed.

Reg. 49,490, 49,493 FN2 (Aug. 16, 2012) (“While we expect that these avoided emissions will result

in improvements in air quality and reductions in health effects associated with HAP, ozone and

particulate matter (PM), as well as climate effects associated with methane, we have determined

that quantification of those benefits and co-benefits cannot be accomplished for this rule in a

defensible way.”). Where, as here, there is no existing system for methane emissions reductions

(much less a “best” system) that has been adequately demonstrated to predicate a methane

emissions performance standard, EPA’s authority under Section 111(d) remains constrained with

respect to existing oil and gas sources.

VIII. EPA SHOULD CONSIDER VOLUNTARY PROGRAMS AND OTHER MECHANISMS (I.E.,

NO RULEMAKING)

Prior to adopting regulations specifically regulating methane emissions from the transmission

and storage sector, the Obama Administration should evaluate existing programs related to the

transmission and storage of natural gas to determine if there are readily available mechanisms to

achieve methane emission reductions without development of a significant new regulatory program.

Such programs include EPA’s own Natural Gas STAR program.

Significantly, Kinder Morgan believes that there are more effective ways to reduce methane

emissions from the transmission and storage sector than those discussed in the EPA White Papers.

More specifically, Kinder Morgan recommends that the Obama Administration take necessary steps

to reduce the number of unnecessary blowdowns from the transmission and storage sector caused

by changes in the class location of pipeline segments. Under PHMSA regulations, pipelines are

subject to different requirements based upon, their “class location.” Class location is determined on

a location-by-location basis depending upon the density of the buildings along the sliding mile of the

pipeline. PHMSA regulations currently require installation of new pipe with limited exceptions, when

population density changes the class location of the pipe. To replace a pipeline, the pipeline

operator must blowdown the entirety of a segment of pipe (approximately 10 to 15 miles) in order to

replace the pipe along any portion of that segment. In a blowdown, the pipeline operator releases to

the atmosphere the entire contents (pure natural gas) of the pipeline.

These emissions, which vary depending upon the diameter of the pipeline, can exceed those

anticipated from other sources anticipated for reduction by EPA, specifically leaks. For example, a

blowdown of a 15 mile segment of 30” natural gas pipeline will result in a release of approximately

20MMcf of natural gas (or methane). In lieu of replacing the pipelines when there is a change in

class location, operators have proposed that PHMSA revise its regulations to allow the use of

integrity management programs (including pigging and close interval surveys) which will provide an
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additional margin of safety while avoiding wasteful replacement of pipe and otherwise unnecessary

blowdown emissions. By adopting such integrity management systems, PHMSA would ensure

safety appropriate to a particular class, while significantly reducing emissions of methane far beyond

the emissions contemplated by the current white papers.

To put the emissions from pipeline blowdowns necessitated by changes to class location in

perspective, Kinder Morgan currently has to blowdown on average 8 to 10 segments per year under

PHMSA’s regulations for class location. See 49 C.F.R. § 192.611. Collectively, upgrading 10

segments of pipeline per year would result in approximately 200 MMcf (91,300 metric tons of CO2e)

of methane emissions. Kinder Morgan operates approximately 25% of the nation’s transmission

lines, so nationwide the amount of methane released to unnecessarily upgrade pipelines is

significant Instead, if PHMSA would adopt revised regulations allowing for integrity management in

lieu of pipeline replacement, these tons of methane could be preserved each year. Revisions to

provide an alternative to pipe replacement under the PHMSA class location rules to reduce pipeline

blowdown should be promoted in lieu of a more detailed regulatory program by EPA. In doing so,

however, EPA must be cognizant of the fact that pipeline operators frequently cannot always control

the timing and need for blowdowns in emergency situations to maintain pipeline integrity and assure

safety. However, where such blowdowns are not required for safety, and instead are driven by

existing regulations (as described above), the Obama Administration should adopt revisions to

reduce the frequency of those blowdowns.

IX. LESSONS LEARNED

Prior to initiating any rulemaking, EPA should better understand the difficulties and

uncertainties related to implementation of methane regulations, such as those adopted in Colorado

in February 2014. Those regulations have been promoted by many (including the environmental

community) as setting forth appropriate, technologically achievable, and cost-effective levels of

methane regulations. Kinder Morgan maintains not only that the methane regulations in Colorado (a

state in which Kinder Morgan operates) are not as cost-effective as touted, but are also ambiguous

and uncertain in many instances. After the rulemaking, the Colorado Department of Public Health

and Environment, Air Pollution Control Division developed a draft of frequently asked questions,

provided one guidance memorandum, and has undertaken other efforts to evaluate information

relevant to the adopted regulations. Though Kinder Morgan appreciates the time and commitment

that the Air Pollution Control Division has devoted to resolving the many outstanding questions and

issues, the presence of these significant issues warrants careful consideration by EPA as to the

available data, current technologies, and costs associated with any requirements to reduce methane

in the oil and gas sector. EPA should take the necessary time to evaluate emissions data (including

from ongoing studies), better understand available technologies (including from implementation of

the Colorado program and pending studies), and provide operators time to provide more accurate

assessments of costs (particularly as those operators in Colorado learn more about the true costs of

compliance), before proceeding with any decisions as to reductions of methane (or mechanisms for

such reductions).
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X. KINDER MORGAN SOURCE SPECIFIC COMMENTS

A. General Comments

As previously stated, Kinder Morgan incorporates by reference API and INGAA comments

related to emissions information presented by EPA in the white papers. Specific concerns noted by

API and INGAA and shared by Kinder Morgan include but are not limited to:

 EPA’s White Papers should distinguish between studies (which provide original or additional

emission data) and papers (which use existing emissions data).

 EPA’s White Papers should contain a detailed assessment or critique of each of the studies

and papers cited, including other studies or papers that have refuted the information in those

studies and papers.

 EPA’s White Papers should acknowledge the need to update some of the emissions data

relied upon both by EPA and many of the papers cited by EPA.

 EPA should rely upon the GHG reporting data as the primary source of measured emission

data in the future and compare that data with other studies and data sources.

 EPA overstates the emissions factors for several of the sources.

Importantly, EPA should reference or acknowledge the numerous ongoing initiatives and

studies to understand methane emissions from the natural gas sector, including ongoing studies

related to pneumatics and well liquids unloading. Kinder Morgan incorporates by reference

comments by API and INGAA on these issues. Kinder Morgan has been engaged with Colorado

State University (CSU), Environmental Defense Fund (EDF), and other industry partners to develop

additional information regarding methane emissions from the transmission and storage sector.

CSU is the lead investigator for this study and they are working with EDF and seven transmission

and storage industry companies, including Kinder Morgan, to analyze the methane emissions

associated with onshore natural gas transmission compressor stations and underground natural gas

storage facilities located within the United States. Together, these industry partners represent

roughly 60 to 70 percent of the overall transmission and storage industry segment in the United

States.

The CSU study includes a combination of on-site field measurements at compressor stations

in the transmission sector and at underground natural gas storage facilities and an analysis of

existing methane emissions. The combined on-site field measurements and industry partner data

has been used to develop a computer model that will seek to estimate the overall U.S. methane

emissions associated with this transmission and storage segment to augment the methane

emissions currently reported for the transmission and storage segment under 40 C.F.R. Part 98,

Subpart W of the Greenhouse Gas Reporting Program, and the EPA’s National GHG Emissions

Inventory. This transmission and storage methane emissions study is expected to be released

during the second half of 2014. Any evaluation of mechanisms for achieving methane reductions

from the transmission and storage sector should be delayed until after the release of that study and

EPA has time to assess the data from that study which will specifically cover components leak rates.
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Furthermore, EPA seeks to assess costs of development and incorporation of technologies

but does not indicate how EPA plans to analyze the cost per ton of emission reduced to determine

cost-effectiveness of the potential reduction technologies or requirements. While the EPA White

Papers discuss the cost of equipment and technologies available to reduce methane emissions from

oil and gas sources, the EPA White Papers do not evaluate the cost-benefit of methane (or even a

CO2 equivalent) emissions reductions achieved through implementation of the proposed emissions

mitigation techniques. Lack of a substantiated cost-benefit analysis constitutes a fundamental error

in EPA’s economic analysis. Kinder Morgan asserts that EPA’s proposed mitigation techniques are

not all, in fact, cost-effective for the transmission and storage sector.

Not only has EPA not presented a measureable cost per ton of methane reduced, EPA has

not presented substantiated data to support its conclusion that any such costs would be

reasonable. Kinder Morgan believes the general costs presented in the White Papers are in fact

much greater than EPA estimates and the benefits much lower. In EPA’s recently proposed Clean

Power Plan—which proposes control techniques to reduce CO2 pollution from power plants—EPA

estimated, for example, that the average cost of CO2 reductions achieved through gas conversion or

co-firing would range from $83.00 per metric ton of CO2 to $150 per metric ton of CO2. See EPA,

Proposed Rule, No. EPA-HQ-OAR-2013-0602, “Emission Guidelines for Existing Stationary

Sources: Electric Utility Generating Units,” at 240 (June 2, 2014) (unpublished in Federal

Register). In its economic analysis, EPA contends that the “system of emissions reductions”

proposed would achieve “meaningful CO2 emission reductions at reasonable costs.” See id. at

252. The same cannot be said for EPA’s proposed mitigation techniques to reduce methane

emissions in the transmission and storage sector, which are expected to far exceed this range of

values, particularly for smaller sources of emissions.

In fact, EPA chose not to directly regulate methane under the New Source Performance

Standards OOOO two years ago in order to collect more accurate, comprehensive, sector-specific

data upon which to base any methane-focused rule to regulate the oil and gas industry. See 77

Fed. Reg. 49,490, 49,493 FN2 (Aug. 16, 2012) (“quantification of those [methane] benefits and cobenefits cannot be accomplished for this rule in a defensible way”). A mere two years (August 2012

to April 2014) has not been nearly enough time for EPA to develop a comprehensive, accurate, and

defensible set of data to demonstrate the cost-benefits of regulating methane in the oil and gas

industry, particularly the transmission and storage sector. Furthermore, because the impetus and

results of reduction of methane is not primarily a health issue, the costs would need to be lower per

ton of reduction (as set forth in the Clean Power Plan). Below Kinder Morgan addresses concerns

and provides comments on the Compressor, Leaks and Pneumatics White Papers, in turn.

B. Compressors

1. Kinder Morgan Compressors

Kinder Morgan has a total of approximately 1,360 reciprocating compressors with

approximately 280 at processing facilities and 1,080 in the transmission and storage sector.

Approximately 20 of the reciprocating compressors at processing facilities are regulated under

NSPS OOOO and any new reciprocating compressors at Kinder Morgan’s processing facilities

would also be regulated under NSPS OOOO. NSPS OOOO requires Kinder Morgan to replace rod

packing on reciprocating compressors installed after October 15, 2012, every 26,000 hours or 36
12

months of operation. Kinder Morgan has a total of 150 centrifugal compressors using wet seals, with

2 at processing facilities and 148 in the transmission and storage sector. Kinder Morgan has a total

of 194 centrifugal compressors using dry seals, with 4 at processing facilities and 190 in the

transmission and storage sector. None of the wet seal centrifugal compressors at processing

facilities are regulated under NSPS OOOO; however, any new wet seal compressors at Kinder

Morgan’s processing facilities would be regulated under NSPS OOOO.

2. Emissions Assessment From Compressors

Kinder Morgan has significant concerns about the accuracy and scope of the emissions

estimates and studies utilized by EPA, particularly with respect to the transmission and storage

sector. In general, EPA should wait for further information under development as part of the Subpart

W reporting program and through existing and soon-to-be completed studies specific to the

transmission and storage sector.

a. EPA Cited Studies

In the Compressor White Paper, EPA identifies several currently available studies that

quantify methane emissions and reduction technologies from the natural gas sector, including

production, processing, transmission, storage, and distribution operations. Those studies included

studies conducted by the Gas Research Institute (1996), URS and the University of Texas (2011),

EPA (2012, 2013 and 2014), API and ANGA ((2012), and ICF International for the Environmental

Defense Fund (2014).

b. Comparison of Studies

Kinder Morgan finds it difficult to compare or characterize the emissions from reciprocating

and centrifugal compressors from each of these studies because the emissions data, as identified in

the Compressors White Paper, are presented in different forms in each of the studies. Kinder

Morgan provides the methane emissions reporting method for reciprocating and centrifugal

compressors in the natural gas transmission and storage sector for each study Table 1 below:

Table 1

Study Methane Emissions Reporting Form

Reciprocating Compressor Rod

Packing

Centrifugal Compressor Wet

Seals

Gas Research Institute

(1996)

Avg. Methane Emissions (Mscf/yr)1

and Annual Methane Emissions

MT/yr based on a population of

8195 compressors

Avg. CH4 Emissions (Mscf/yr)

URS and the University of

Texas (2011)

Avg. CH4 Emissions (Mscf/yr) Avg. CH4 Emissions (Mscf/yr)

US EPA Oil & Gas NSPS Methane Tons per compressor/yr Methane Tons per

1 Mscf/yr = thousand cubic feet per year, scf/h = standard cubic feet per hour, and scf/min = standard

cubic feet per minute.

MT/yr = metric tons per year (also commonly referred to as tonnes).
13

(OOOO), EPA 2011b &

2012a

compressor/yr

US EPA National GHG

Emission Inventory, EPA

2014

Annual Methane Emissions MT/yr

based on a population of 8247

compressors

Annual Methane Emissions

MT/yr based on a population

of 729 compressors

US EPA GHG Reporting

Program, EPA 2013

Annual Methane Emissions MT/yr

based on a population of 2317

compressors

Annual Methane Emissions

MT/yr based on a population

of 763 compressors

American Petroleum

Institute and the American

Natural Gas Alliance (2012)

Methane emission rate for rod

packing not reported in this study.

Annual methane emissions of

190,573 tons from oil and gas

production sector.

ICF International for the

Environmental Defense

Fund (2014)

ICF identified a rod packing

emission rate of 57 scf/h1

Methane emission rate range

of 40-200 scf/min per

compressor

In order to conduct an analysis of the methane emissions from rod packing or wet seals, it is

important to establish some consistent baseline emission rate. The emission rates in each of the

studies identified in the Compressor White Paper all vary. Establishment of a consistent baseline

emission rate or range of emissions is important for development of future national inventories and

future policy decisions.

From the sample sets identified in each of the studies, it is readily apparent that data from

the GHG reporting program (GHGRP) provides the most recent and extensive dataset of methane

emissions measurement data. The GHGRP data included in the Compressor White Paper was

derived from 2012 measurements at reporting sources. Kinder Morgan acknowledges that a portion

of the GHGRP dataset includes emissions based on Best Available Monitoring Method (BAMM)

calculations; however, even considering that fact, the GHGRP provides the most extensive dataset

of actual methane emissions measurement data and continues to improve.

A direct comparison of compressor specific methane emission rates from the 2012 GHGRP

data (released by EPA in 2013) with the 2014 GHG Emission Inventory with respect to the

transmission and storage sector evidences that the US EPA National GHG Emission Inventory for

Compressors in those sectors significantly overstate methane emissions. See Table 2 below for

compressor population estimates, annual emissions per compressor and average methane

emissions rates per compressor in the transmission and storage sector.

Table 2

US EPA National GHG

Emission Inventory, EPA 2014

US EPA GHG Reporting

Program, EPA 2013

Transmission Reciprocating Compressors (Rod Packing)

Compressor Population 7,235 2,008

Compressor Annual Methane

Emissions (MT/yr) 1

773,294 75,809

Average Methane Emission Rate per

Compressor (MT/yr) 1

106.9 37.8
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Storage Reciprocating Compressors (Rod Packing)

Compressor Population 1,012 309

Compressor Annual Methane

Emissions (MT/yr) 1

150,225 7,658

Average Methane Emission Rate per

Compressor (MT/yr) 1

148.4 24.8

Centrifugal Compressors (Wet Seals, Transmission & Storage)

Compressor Population 729 763

Compressor Annual Methane

Emissions (MT/yr) 1

255,173 26,582

Average Methane Emission Rate per

Compressor (MT/yr) 1

350.0 34.8

Centrifugal Compressors (Dry Seals, Transmission & Storage)

Compressor Population 95 Not reported

Compressor Annual Methane

Emissions (MT/yr) 1

21,504 Not reported

Average Methane Emission Rate per

Compressor (MT/yr) 1

226.4 Not reported

1MT/yr = Metric Ton per year (also commonly referred to as tonnes).

Since the GHGRP is the most recent and comprehensive dataset, Kinder Morgan

recommends that EPA use data from the GHGRP program as the basis for establishment of

baseline emission rates, for incorporation into future national inventories and for any future policy

decisions.

Data Discrepancies & Uncertainty

As indicated above, evaluation of the 2012 GHGRP data compared to EPA’s 2014 National

GHG Inventory indicates that the average methane emission rate (MT/yr) per compressor is

significantly lower for reciprocating and centrifugal compressors in the natural gas transmission and

storage sector than what is reported in EPA’s 2014 National GHG Inventory. In light of these

discrepancies, EPA should refuse to rely upon the inaccurate 2014 National GHG Emission

Inventory and instead should include the relevant 2013 GHGRP data together with the existing 2012

GHGRP measurement data to provide further information regarding compressor emissions and to

develop a more accurate average emission factors for reciprocating and centrifugal compressors,

particularly in the transmission and storage sector. These average emission factors should also be

incorporated into development of the 2015 National GHG Inventory (for the 2013 calendar year).

In addition to its concerns about the comparability of the studies and the validity of the

National GHG Inventory, Kinder Morgan has particular concerns about important information EPA

omitted from its discussion on the GRI/EPA Methane Emissions from the Natural Gas Industry,

Volume 8: Equipment Leaks (GRI/EPA, 1996a). Specifically, EPA fails to acknowledge in the

Compressors White Paper the existence and extent of emission factor uncertainty for reciprocating

compressor seal (rod packing) leaks in the GRI/EPA data. “Uncertainty” identifies and quantifies

errors involved in a measurement and combines those to form an uncertainty value. As outlined in

Table 4-15 of GRI/EPA, 1996a, the emission factor uncertainty for reciprocating compressor seal

(rod packing) is extremely high at 96%. This means that the actual emission factor for compressor

seal leaks ranges anywhere from 397 Mcf/comp-yr to 186 Mcf/comp-yr. This significant level or
15

amount of uncertainty should be considered before developing rules to control this emission source

and in fact counsels against development of regulations at this time. EPA should also acknowledge

the uncertainty factor in Compressors White Paper Table 3-2, which outlines the summary of

reciprocating compressor seal (rod packing) emission factors.

This high level of uncertainty undoubtedly has an effect on the 2014 GHG Inventory from the

Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1190-2012 (U.S. EPA, 2014) which

calculates net methane emissions using the emission factors based on the GRI/EPA study (GRI/U.S.

1996a). As mentioned above, those emission factors have a range of uncertainty from +/- 53% to

+/-276% (GRI/EPA, 1996a). Based off of this information, the methane emissions per industry, per

piece of equipment calculated in the Compressors White Paper Table 3-9 have little validity.

Another emissions reference relied upon by EPA, Development of the New Source Performance

Standards (NSPS) For Oil and Natural Gas Production (U.S. EPA, 2011b and U.S. EPA, 2012a),

also utilized the GRI/EPA emission factor having an uncertainty of 95% in estimating emissions from

reciprocating compressor rod packing in the transmission and storage industry segments. Again,

the uncertainty in the emission factor should be outlined in Compressors White Paper Table 3-10 in

the column following the identified methane emission factor. Compressors White Paper Table 3-11

indicates (based on the outdated emission factors) that the transmission and storage segments have

the highest methane emissions per ton per compressor per year. However, the significant amount of

uncertainty precludes EPA from drawing conclusions from the data provided in this analysis due to

the large uncertainty in the basis of the calculations. In fact, and as noted in INGAA’s comments,

the emissions for reciprocating compressors are over 7 times higher in the national inventory than

Subpart W and emissions for centrifugal compressors are over 30 times higher in the national

inventory than Subpart W.

c. Additional Studies

Pipeline Research Council International Report

In addition to further increasing its reliance on the GHGRP dataset, EPA should consider

review of additional studies regarding methane emissions and reduction techniques. Kinder Morgan

has been and continues to participate in industry sponsored research regarding methane emissions

and reduction techniques. As noted above, Kinder Morgan is currently participating in the

EDF/Industry collaborative methane emissions inventory study being conducted by CSU. Kinder

Morgan is also participating in a comprehensive study by the Pipeline Research Council

International, Inc. (PRCI) on methane reduction techniques. The PRCI study is expected to provide

a summary of existing GHG emission reduction technologies and work practices for application at

transmission and storage compressor stations. Both the CSU and PRCI studies are anticipated to

be finalized later this year.

Kinder Morgan recommends that the EPA delay any decisions on future methane reduction

policies until the results from these studies can be produced, reviewed, and coordinated with DOE’s

efforts under the Methane Strategy. Kinder Morgan believes that these crucial studies will provide

significant new information regarding actual methane emissions and potential emission reduction

techniques for the transmission and storage sector. Therefore, EPA should include the results from

these studies into any future policy decisions.
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d. Kinder Morgan Emissions Data

Kinder Morgan has certified and submitted the following number of GHG reports in e-GGRT

in 2011, 2012, and 2013 as a result of being subject to reporting under Subparts C, W, and/or NN of

40 C.F.R. Part 98.

 2011: 112 facilities reported.

 2012: 136 facilities reported.

 2013: 141 facilities reported.2

The vast majority of the above facilities triggered the requirement because of combustion emissions

exceeding 25,000 tons, which led to the need to complete annual surveys and measurements under

Subpart W. Table 3 provides a summary of Kinder Morgan actual compressor measurement data

compiled from 2011 to 2013 for the facilities that triggered GHG reporting under 40 C.F.R. Part 98

and approximately 212 additional facilities that did not trigger GHG reporting where compressor

measurements were also performed over the last 3 years.

Table 3

Kinder Morgan Methane Emission Rates for Reciprocating and Centrifugal Compressors

(2011 to 2013 Subpart W Measurements)

Compressor

Emission Source

KM Total # Compressor

Units Measured*

KM Total # Compressor

Units w/Methane

Emissions**

KM Average Methane

Emission Rate per

compressor

(scf/minute)

KM Average

Methane Emission

Rate per

compressor

(MT/year)

Recip. Rod

Packing

1250 1152 3.89 39.23

Recip. Blowdown

Valves

1088 384 1.55 15.62

Recip. Isolation

Valves

1190 863 4.63 46.72

Centri. Wet Seal

Vents

73 53 0.88 8.85

Centri. Blowdown

Valves

160 62 9.21 92.96

Centri. Isolation

Valves

410 198 3.02 30.43

Centri. Dry Seal

Vents***

15 15 1.66 16.78

*Total number of compressors measured by Kinder Morgan from 2011 to 2013. This total includes those facilities that triggered

reporting under Subpart W and some additional facilities not reported under Subpart W.

**Total number of compressors that had measurable methane leaks from 2011 to 2013.

***Additional measurements that are not required by Subpart W for centrifugal dry seal compressors.

Recip.: reciprocating

Centri: centrifugal

scf/minute: standard cubic feet per minute of methane

MT/year: metric ton per year of methane mass emissions = scf/minute x 60 x 8760 x 0.0192 kg/ft^3 x 0.001.

Although this table provides a cumulative roll-up of the first three years of Subpart W

monitoring data with respect to compressor, the data indicate that natural gas compressors will have

2 Reported facilities vary year to year based upon sale and purchase of assets since the prior reporting

period.
17

some amount of leakage every year due to the inherent nature of their operation at high gas

pressures, temperatures, vibrations, and the amount of piping and equipment required for operation.

In order to minimize the amount of leakage and product loss, formal and consistent operating, repair,

and replacement practices should be used to reduce the methane leakage associated with

compressors, and specifically those components of compressors with the greatest emissions.

Importantly, the compressor emission sources with the highest per compressor methane

emission rates are the centrifugal blowdown valves and reciprocating compressor isolation valves.

Here, however, the repair or replacement of these valves is not performed on a regular basis

because it requires the complete isolation and blowdown of the respective compressor units in order

to perform this repair or replacement. In fact, in the short-term, the repair or replacement activity at

these sources could result in greater methane emissions vented to atmosphere thereby minimizing

or cancelling out any short-term reductions achieved through the repair or replacement.

The Kinder Morgan annual emission rate per compressor per year (in MT/year) in the last

column is similar to the reciprocating rod packing emissions data reported for the overall

transmission and storage segment under EPA’s GHGRP, and the Kinder Morgan data is much lower

than the wet seal emissions data reported for the overall transmission and storage segment under

EPA’s GHGRP. The Kinder Morgan annual emission rate per compressor for reciprocating rod

packing and wet seal vents is also several times lower than the emissions reported under the EPA’s

National GHG Emission Inventory Report for 2014. Kinder Morgan conservatively based the

MT/year rate on 8,760 hours for each of the different emission source categories in order to provide

a common comparison between the different emission sources. For the reciprocating and

centrifugal isolation valve sources, this 8,760 hour/year assumption is overly conservative since

these valves are only used when depressurizing and isolating a compressor; a rare occurrence for

many compressors. In actuality, the amount of time spent in this depressurized mode (which

requires the closing of the isolation valves) is roughly ten (10) to thirty (30) percent of the year for

most compressors depending upon its frequency of utilization.

Interestingly, the emission source with the lowest methane emission rate is centrifugal wet

seal vents. Based on this measured data from 2011 to 2013, these centrifugal wet seals appear to

be functioning as designed to minimize gas leakage to atmosphere. Kinder Morgan also includes

data from fifteen (15) measurements that were taken on some of our centrifugal dry seal vents.

Although these measurements are not required under Subpart W, Kinder Morgan decided to take

measurements on some dry seal centrifugal compressors in order to gain a better understanding of

the potential for leakage from these types of units. Based on these measurements, it shows that

leakage may occur from dry seal units at a rate higher than wet seal units. Notwithstanding, Kinder

Morgan’s data indicates that dry seal emissions are lower than EPA’s emissions data presented in

the White Papers. This empirical data demonstrates that retrofitting wet seal compressors with dry

seals may not result in the expected methane reductions, but rather the opposite effect of potentially

increasing methane leakage. Even though this data shows that dry seals do have methane leakage,

it is still much lower than other compressor emission categories.

In summary, Kinder Morgan hopes that this actual measured data collected over the last

three years provides EPA some additional insight and direction on the emissions associated with

reciprocating and centrifugal compressors and the sources that have the potential for the greatest

level of methane reduction while thoroughly considering any technical obstacles that could prevent

achieving those reductions.
18

3. Technologies for Methane Reductions

EPA sets forth its understanding of potential technologies available to reduce methane

emissions from rod packing associated with reciprocating compressors and from wet seals

associated with centrifugal compressors. Kinder Morgan provides more specific information

regarding the availability, usability and costs of those technologies below.

a. Reciprocating Compressor

Rod Packing

Section 4.0 of the Compressor White Paper describes the available compression emission

mitigation techniques. EPA specifically references the importance and benefits from replacing rod

packing on a certain frequency to ensure that emissions from rod packing are reduced, as well as

new technologies that enable emissions to be captured and either routed to a combustion device or

a useful process.

 Rod Packing Replacement

As described in the Compressors White Paper packing rings wear over time allowing more

natural gas to escape around the piston rod. Kinder Morgan agrees that performing rod packing

replacements is important in reducing emissions as well as ensuring that our equipment is being

properly maintained but thinks that the time frame for replacement should be dictated on the actual

wear of the rings, rather than a prescriptive interval. Kinder Morgan would recommend

implementation of a rod packing condition based maintenance program rather than a specified time

based maintenance program.

 Vapor Recovery Unit System

Section 4.2.1 of the Compressors White Paper describes recovery of the natural gas leaking

past the piston rod packing by utilizing a vapor recovery unit (VRU) system. In Kinder Morgan’s

experience (with utilizing VRUs to control emissions from storage tanks), these systems inherently

have issues and are unreliable. Importantly, VRUs have to be completely sealed; a task incredibly

difficult to achieve. In fact, even with the use of a natural gas or nitrogen blanket, the systems pull

air, more specifically, oxygen and moisture into the system. This influx of oxygen can cause safety

concerns related to the potential for explosion and internal corrosion of the pipeline (NACE

96612).3 When VRUs are used to control tanks, the natural gas liquids have a tendency to also get

collected with the captured gas; inevitably destroying the associated compressor. Currently, in those

contexts in which Kinder Morgan uses VRUs, Kinder Morgan has developed systems to shut the

VRU and associated compressor down in such an event. This needs to be considered when

attempting to transfer this technology to rod packing vent lines and is further described below.

As noted in the Compressors White Paper, the use of a VRU to capture rod packing

emissions would require installation of a small compressor to compress this low pressure/low

3 NACE International, The Corrosion Society, “96612 Effect of Oxygen on the Internal Corrosion of

Natural Gas Pipelines.”
19

volume packing leakage to the pressure rate necessary to pipe it to the VRU. Not only is this an

additional emissions source at the facility, but the use of a small compressor creates an even greater

likelihood of creating a vacuum and causing additional leakage from the rod packing or drawing air

into the system. As with tanks, drawing air into the system creates a safety concern as it can cause

an explosion as well as internal corrosion of the pipeline (NACE 96612). For example, some

compressor stations currently have pressure switches installed in the vent pipe set at six inches of

water (approximately 0.25 psi) for shutdowns. This safety mechanism has been put into place

because if the pressure gets too high it could cause a safety issue. Installing a small compressor to

draw a vacuum could render this safety shutdown inoperable. The possibility of additional oxygen in

the gas needs to be considered when determining if it is safe to use the captured gas elsewhere in

the process as suggested in the Compressors White Paper.

In addition, liquids such as engine oils and lubricants will cause severe problems if they are

not removed before reaching the VRU’s compressor. Liquids cannot be compressed; therefore, if

such liquids were to ever reach the VRU compressor it would cause serious damage to the

equipment. A control method would be required to shut the system down if liquid is detected in the

line. If this were to occur, the rod packing vent would be required to vent to atmosphere. If this

flexibility was not allowed and the unit was required to be shutdown, the additional emissions caused

by the subsequent blowdown should be considered in the emission reduction benefit analysis. A

similar situation could occur in the reverse direction. Specifically, to mitigate pulling any additional

methane out of the system a very small pressure differential is targeted. If the system is ever found

to have a negative pressure then that would allow liquids to get into the crankcase, which would in

turn damage the large reciprocating compressor. In the case of a compressor at a transmission

compressor station, if natural gas demand is high and the unit needs to run there could be serious

repercussions if a compressor has to be shut down for maintenance due to liquids getting into the

crankcase. These common issues also increase the amount of maintenance required at a station

and subsequently the annual operating costs.

Section 4.2.1 of the Compressor White Paper is inaccurate in assuming that if the proper

vapor recovery equipment is already available at the facility, capturing the rod packing gas would be

as simple as routing the rod packing vents to the tanks allowing the gas to be picked up by the VRU.

The vent systems for different compressors should not be tied together for safety reasons; therefore,

each compressor would require its own VRU. Separate vents eliminate the chance of excessive rod

packing leakage from one unit to cause issues with other units. Therefore, it is incorrect in

Compressor White Paper Section 4.2.3 to assume that the incremental cost of additional piping to

capture rod packing vent gas at a facility with a VRU already present can be recovered from the

value of additional gas captured. The cost of implementing the system would need to be multiplied

by the number of compressors at a station, which in some cases could be greater than ten.

Another safety concern with utilizing a VRU on rod packing vent lines is that if a malfunction

were to occur causing negative pressure to misdirect the natural gas back toward the rod packing, it

would cause the area surrounding the compressor to be engulfed in natural gas, which has the

potential to cause a serious flash fire.

The use of a flare to control rod packing emissions captured with a VRU and that has no

other meaningful use onsite would not be cost effective. First, the level of emissions from rod

packing would not be sufficient to run the flare without use of additional pilot gas. In fact, one flare

vendor has indicated to Kinder Morgan that 78 standard cubic feet of gas per hour (scfh) of pilot gas
20

is required for their flares ranging in diameter from 4 inches to 24 inches. Assuming $4/Mcf of gas,

that would be an additional cost of $2,733.12 per year per flare (or $3,711,576 total for Kinder

Morgan’s operation) in pilot fuel since the natural gas from the rod packing would not be sufficient to

run the flare. In addition to the fuel required for the pilot gas, if the flare would be required to meet

40 C.F.R. Section 60.18 or 40 C.F.R. Section 63.11, General Control Device and Work Practice

requirements, additional fuel would be needed to increase the heat content of the gas to ensure

compliance. The associated costs (both environmentally and economically) of the additionally lost

fuel would need to be considered in the cost effectiveness of this control method. In addition, it

should be noted that along with the criteria pollutants formed via combustion (e.g. CO and NOx),

CO2 is formed by oxidation of fuel hydrocarbons, nitrous oxide is formed in combustion zones and

some fuel methane escapes combustion.

Unlike upstream operations, transmission and storage compressor stations rarely have

existing flares or vapor recovery systems that would allow an operator to transfer the vapor recovery

technology for use on rod packing vent lines. Such technology has many safety and operational

implications that were not addressed in the Compressors White Paper. There appears to be no

sound research or industry experience that points to vapor recovery being a viable control

technology for rod packing emissions, particularly in the transmission and storage sector. Additional

research would be required to determine technical feasibility and address these safety concerns.

 REM SlipStream® SA Technology

The Compressors White Paper references REM’s SlipStream® SA Technology for capturing

and recovering methane emissions from rod packing systems. The SlipStream® SA Technology

utilizes the turbocharger on the engine as a venturi to draw a slight vacuum on the vent piping. After

going through a knock-out drum and a demister to remove any oils and lubricants it is feed to their

SlipStream® equipment. Their system monitors the gas flow back into the system which eases airto-fuel ratio and safety concerns. The vented gas is then reintroduced into the intake air after the

engine air filter. By re-entering the steam into an already low pressure stream, no recompression is

required. While this technology has been applied on several rod packing systems within the

industry, Kinder Morgan has safety concerns related to the REM SlipStream® technology due to the

potential that excess natural gas can be allowed into the system and has the potential for engine

damage or explosion. At best, the REM SlipStream® technology should be viewed as a

developmental technology. Further applications and operational history would be required to assure

that safety concerns, system reliability and other potential operating issues have been resolved prior

to any mandatory requirement to implement this technology nationwide.

Alternative Technology to Control Compressor Emissions

Instead, Kinder Morgan suggests alternatives to those provided by EPA in the Compressor

White Paper. As noted above, Kinder Morgan data related to compressor methane emissions

indicates that other compressor events, including vented emissions from planned maintenance, may

result in greater methane emission reductions than those from rod packing. As such, Kinder Morgan

recommends that EPA re-evaluate the most relevant sources of emission from compressors

(particularly in the transmission and storage sector) and further evaluate practices that assist in

reducing those emissions.
21

 Compressor Burn Down Technique

Several Kinder Morgan compressor stations use a compressor piping burn down system to

reduce the volume of natural gas vented to atmosphere during planned maintenance activities. This

burn down technology is applicable for high pressure compressors and is not related to rod packing

vents. These burn down systems involve piping, valves and regulators required to connect

individual compressor unit piping to the station fuel gas system. When connected for service, the

station fuel gas system uses the compressor piping as an alternative supply of natural gas. This

process allows the operating pressure contained in the compressor piping to be lowered to the

normal station fuel gas pressure (typically 100 – 125 psi) before the compressor piping is vented to

atmosphere prior to planned maintenance. Though this can be done in certain circumstances, the

compressor burn down system has limited applicability due to the compressor station design and

configuration. Broad application would not be appropriate; only a case-by-case application,

considering safety (and other) concerns, would be reasonable.

Economic Evaluation

 Rod Packing Replacement

The cost for a rod packing replacement is much more complicated than described in the

Compressor White Paper. Kinder Morgan contends that not only are the costs of $1,620/cylinder too

low for piston rings, but there are also many other costs that could be incurred during a rod packing

replacement. From our experience, the cost of piston rings can range from $1,760 on a 1600 hp

compressor to $3,050 on a 5500 hp compressor without the cost of associated labor required for

installation. In addition, whenever a rod packing replacement is to be performed, the entire cylinder

must be taken apart. At that time, other pieces of equipment could be identified as needing

maintenance including, but not limited to wiper packing replacement or repair, rod replacement or

repair and packing case replacement or repair. These additional costs can add up to approximately

$17,900/cylinder. A compressor blowdown would also be required at the time of a rod packing

replacement. The associated cost from the gas lost also needs to be accounted for in the economic

evaluation.

 Vapor Recovery Unit System

For any emission control technology that EPA were to mandate, it has to recognize that there

is no economic benefit for the transmission and storage segment to capture the methane emissions

lost since the transmission company does not own the natural gas. The control equipment would not

have a payback period, similar to other segments of the industry. Instead, if required to put on

controls, the tariff rates would have to be increased to supply the gas which would be passed on to

the consumer. In sum, Kinder Morgan has significant concerns with any requirement to control or

reduce methane emission from rod packing using a VRU system.

 REM SlipStream® SA Technology

The cost of the REM SlipStream® SA Technology is dependent on whether the compressor

requires a standalone system, which would be the most likely choice for an existing compressor or

an integrated panel, which is applicable for new compressors. When doing a cost analysis on this
22

control methodology, the standalone system should be considered for a range of different

compressor manufacturer model types.

b. Centrifugal Compressors (wet seal)

Centrifugal compressors require seals around the rotating shaft to prevent high-pressure

gases from escaping the compressor casing. Traditionally, centrifugal compressors used a series of

rotating rings around the compressor shaft to form a barrier to prevent gas from escaping. Seal oil

was used to lubricate the rings and act as an additional gas barrier. Older vintage centrifugal

compressors are commonly equipped with wet seals. Beginning in the late 1980s, centrifugal

compressor manufacturers began install dry seals on new centrifugal compressors. Dry seals do not

use any lubricating oil. New centrifugal compressors currently available for purchase by

transmission and storage operators are equipped with dry seals.

The emission rates for wet seal centrifugal compressors in EPA’s 2014 national inventory are

50,222 scf/day/compressor for transmission and 45,441 scf/day/compressor for storage. In

accordance with the GHGRP requirements, Kinder Morgan has conducted measurements on 73

centrifugal compressors equipped with wet seals between 2011 through 2013. Of those 73

compressors, only 53 compressors had methane emissions. The average methane emission rate

from Kinder Morgan’s 53 centrifugal compressors that had measured leaks was 0.88 scf/min, which

equates to 1,267 scf/day per compressor. See Table 3 above. The average emission rate from

Kinder Morgan’s centrifugal compressors equipped with wet seals is significantly lower than the

average rate identified in EPA’s National Inventory. Based on Kinder Morgan’s experience, a well

maintained wet seal can operate at methane emission rates comparable to or less than dry seals.

While dry seals are standard equipment for new centrifugal compressors, many existing

centrifugal compressors in the transmission and storage sector remain equipped with wet seals.

Wet seals are an integral component of the centrifugal compressor so wet seal replacement with a

dry seal is not a routine, simple, quick, or inexpensive task. Converting an existing wet seal

centrifugal compressor with dry seals involves:

 Removing the oil seal system components and system accessories;

 Reworking the gas compressor to add the dry seal and any associated equipment;

 Rewiring the gas compressor and modifying the control system software; and

 Rebalancing the centrifugal compressor to assure proper operation following the seal

replacement.

Since the compressor seal is an integral component of the centrifugal compressor,

replacement of a wet seal with a dry seal requires that the centrifugal compressor be shut down and

sent back to the manufacturer to compete this replacement. Because of the significant amount of

work required to complete the replacement, the centrifugal compressor would be out of service for

several months. For these reasons, seal replacements are normally coordinated with scheduled

overhauls, compressor restaging, or other compressor maintenance projects.

Costs for replacing a wet seal on a centrifugal compressor will vary based on the compressor

type (aero derivative or industrial type), make, model, physical size, horsepower rating, compressor

and wet seal configuration and the type of dry gas seal selected (single face or tandem face dry gas

seal). Additional considerations relate to the composition of gas being compressed. Dry seals may
23

contain fluoroelastomer or spring-energized polytetrafluoroethylene (PTFE) O-rings depending on

gas composition. Fluoroelastomer O-rings can swell and degrade if exposed to some organic

compounds (such as ketones, amines, esters and some alcohols).

Limited cost data for wet seal replacements is identified in the Compressors White Paper.

The capital costs for replacing wet seals identified in the Compressors White Paper are:

 Subpart W OOOO technical support document $75,000.

 Natural Gas STAR Program (Table 4-4, Transmission and Storage) $75,000.

 ICF International (assumed retrofit capital cost) $400,000.

These studies do not identify the centrifugal compressor type, make, model, horsepower, or

other centrifugal compressor specifications used to develop these capital cost estimates. In recent

years, Kinder Morgan has obtained proposals to replace wet seals on specific Ingersoll Rand (IR)

model CDP24 (July 2012) and Solar Centaur 40 T4702S (May 2014) centrifugal compressors.

These IR and Solar centrifugal compressors are common, but not the only centrifugal compressors,

used in the transmission and storage sector. The capital costs for these wet seal replacements

were:

 IR model CDP24, seal replacement options:

o Option 1 - Oil seal cartridge & internal shaft bearing $ 95,500

o Option 2 – Single dry gas seal cartridge & gas panel $ 309,700

o Option 3 - Tandem dry gas seal cartridge & gas panel $ 376,300

 Solar Centaur 40 T4702S :

o Dry Gas Seal Package System Upgrade $ 800,000

o Seal Gas Filtration (Solar recommendation) $ 65,000

o Total Cost $ 865,000

Based on the proposals obtained, timing for these wet seal replacements ranged from 28 to

30 weeks. The compressors would be out of service for that duration. There is considerable

disparity between the capital cost values provided to Kinder Morgan and the capital cost

assumptions in the studies in the Compressors White Paper. This disparity is likely due to an

inability to compare the specifications on the types of centrifugal compressors identified and used to

develop the cost assumptions in the Compressor White Paper referenced studies.

The studies identified in the Compressors White Paper also provide operating cost and

methane reduction percentage assumptions for centrifugal compressors. Based on the capital cost

disparity identified above, Kinder Morgan would expect similar operating cost and methane reduction

disparities. Any assumptions in the Compressors White Paper regarding the cost effectiveness of

retrofit wet seal replacements would be flawed due to the inaccuracies of the assumed capital and

operating costs.

Kinder Morgan recommends that EPA obtain a list of commonly used centrifugal

compressors within the oil and gas sectors, obtain specific capital and operating costs, and methane

reduction levels for those commonly used centrifugal compressors prior to developing future policy

decisions. EPA would also need to evaluate the timing associated with any requirement to retrofit

the population of centrifugal compressors with wet seals remaining in service within the oil and gas
24

sector. Any wet seal replacement policy or requirement would need to address manufacturer and

other qualified vendor capabilities, parts and material supply, delivery schedules, and impacts to

national gas supply and transportation capabilities.

C. Leaks

Kinder Morgan has an extensive network of pipelines used for transmission of natural gas

exceeding 70,000 miles long. Along the pipeline network, Kinder Morgan operates more than 450

compressor stations to maintain the pressure in the pipeline and allow the natural gas to continue

flowing through the network from source to destination. The compressor stations include

components such as rod packing, centrifugal compressor seals, valves, connectors, pressure relief

devices, etc. which have the potential for leaks. Based on the most recent reporting year, one

hundred and forty-one (141) Kinder Morgan facilities triggered the requirements to report GHG

emissions. The emissions from leaking components from such facilities are a small fraction of the

emissions reported under Subpart W.

Kinder Morgan has significant concerns about the accuracy and scope of the emissions

estimates and studies utilized by EPA, particularly with respect to the transmission and storage

sector. In general, EPA should wait for further information under development as part of the Subpart

W reporting program and through existing and soon-to-be completed studies specific to the

transmission and storage sector.

1. Emissions from Leaks

a. EPA Cited Studies

As noted above, the GHGRP provides the most relevant information related to leaks from the

transmission and storage sector. The Leaks White Paper includes several studies in the natural gas

transmission and storage sector intended to describe the nature of methane emissions associated

with leaking components. The conclusions drawn from these studies, specifically as related to

emissions data and cost effectiveness, should be based on individual sectors such as gas

production, gathering and processing, as well as transmission and storage because there are

significant differences in the operational parameters affecting leaking rates and leak repair cost to

warrant separate analysis for each of the above sectors. Conclusions should not be based on the

analysis of a combined dataset.

b. Kinder Morgan Emissions Data

Kinder Morgan has certified and submitted the following number of GHG reports in e-GGRT

in 2011, 2012 and 2013 as a result of being subject to reporting under Subparts C, W, and/or NN of

40 C.F.R. Part 98.

 2011: 112 facilities reported.

 2012: 136 facilities reported.

 2013: 141 facilities reported.
25

The vast majority of the above facilities triggered the requirement because of combustion emissions

exceeding 25,000 tons, which led to the need to complete annual surveys and measurements under

Subpart W. Table 4 provides a summary of Kinder Morgan actual equipment component leak

counts that were identified with an Optical Gas Imaging (OGI) camera compiled from 2011 to 2013

as well as approximately 212 additional facilities that did not trigger GHG reporting.

Table 4

Kinder Morgan Average Equipment Component Leak Counts

(based on OGI annual surveys from 2011 to 2013)

Equipment

Component

Emission Source

2011

Average #

Components

Leaking

Per Facility

2012

Average #

Components

Leaking

Per Facility

2013

Average #

Components

Leaking

Per Facility

Kinder Morgan

3 Year Average #

Components

Leaking per

Facility

Kinder

Morgan

Total #

Components

Leaking (2011

to 2013)

Connector (comp.

service)

5.52 6.38 6.06 5.96 1203

Connector (non-comp.

service)

3.67 3.93 4.85 4.15 1476

Meters (comp. service) 3.00 0 1.00 2.00 4

Meters (non-comp.

service)

1.21 1.55 1.00 1.32 37

Open ended line (comp.

service)

3.63 4.11 2.79 3.57 368

Open ended line (noncomp. service)1.88 2.16 2.78 2.26 468

PRV (comp. service) 1.93 2.83 3.28 2.73 120

PRV (non-comp.

service)

1.78 1.46 4.10 2.43 221

Valves (comp. service) 5.75 6.66 4.29 5.80 1056

Valves (non-comp.

service)

3.90 3.97 3.01 3.70 1190

Comp. service: component associated with a compressor in gas service

Non-comp. service: component associated with non-compression in gas service

Kinder Morgan notes that in evaluating each individual year of OGI surveys, there is

variability in the number of component leaks from year to year. There is always going to be

variability in the number of leaking components found every year due to the inherent nature of these

operating facilities at very high gas pressures and temperatures, variable weather conditions,

equipment vibrations, and the significant amount of piping required for operation.

c. Other Considerations and Lessons Learned

Case studies from the Natural Gas STAR program indicate that direct inspection and

maintenance (DI&M) programs help reduce costs and enhance profitable leak repair at the partner

facilities where such programs were implemented. The main lesson learned from such studies

indicate that a relatively small number of large leaks contribute most of a compressor station’s

fugitive emissions and a targeted DI&M program helps reduce leaks from components that are

found to most likely leak and are economic to repair. The study also showed that some compressor

stations are more leak prone than others and a DI&M program helps identify those frequent leakers

through survey and focuses repair efforts on those facilities. Such a program also helps develop a
26

system for repairing the most severe leaks first and incorporating minor leaks into regular operation

and maintenance (O&M) practices. The experience of program partners showed a net savings

range of $48,490 to $492,780 based on participation of 2 to 67 compressor station facilities.

d. Directed Inspection and Maintenance Program

Based on the above information and Kinder Morgan’s own experiences, Kinder Morgan

recommends that EPA refrain from developing regulatory command and control requirements to

reduce methane emissions at this time, particularly in the transmission and storage sector. Instead,

operators should either be encouraged to develop (or if necessary, required to develop) a DI&M

program. Kinder Morgan would be willing to work with EPA to provide a sample DI&M plan for

EPA’s consideration as it consider these and other comments.

As noted above, the basic premise of DI&M program is that, at a transmission and storage

facility, a relatively small number of leaking components account for the vast majority of leaking

emissions, and therefore, it is highly cost-effective to focus on identifying that small number of

leaking components and repairing them instead of conducting a full scale leak detection and repair

program. Lessons learned from the Natural Gas STAR partners indicate that 95 percent of methane

emissions in transmission and storage sector occur from 20 percent of the leaky components.

Any DI&M program begins with a baseline survey of all potential leaking components

including screening and measurement followed by identification of candidates for repair and followup survey for future based on specific cost and payback criteria. A DI&M program is a “living”

document and should be tailored to the needs of a specific operator rather than developing a

generalized plan to fit all entities within the transmission and storage sector.

Data sources from EPA, DOE, industry reports, EPA Natural Gas STAR program reports,

industry literature, and engineering judgment and experience identify DI&M as an appropriate GHG

reduction work practice for fugitive emission sources for all potential emitting components at

compressor stations.

There are significant benefits from a DI&M program in Kinder Morgan’s experience with

DI&M. Specifically, the primary benefit of a DI&M program is its cost-effectiveness. A traditional

LDAR program is time-consuming and costly, and emission reduction benefits decrease over time.

Repair of all leaking components found during a traditional LDAR program may require expenditure

of time and resources to gain little emissions benefit and may, as noted elsewhere in these

comments, result in additional emissions associated with blowdowns required to conduct repairs. A

DI&M program, which initially surveys all potentially leaking components or relies on Subpart W

data, targets only those that provide the biggest benefit in terms of GHG reduction when compared

to the repair cost. Essentially, EPA created the Leak Detection portion of Leak Detection and Repair

(LDAR) when it created Subpart W. While Kinder Morgan believes a DI&M program (see discussion

above) is the most effective solution, should EPA decide to enforce an LDAR program, it makes far

more sense to use the existing leak detection under Subpart W as the basis for such a program than

to require additional leak detection surveys at different frequencies.

The Leaks White Paper does not currently address the cost-effectiveness of a DI&M

program at natural gas transmission and storage facilities in lieu of some of the proposed reduction
27

technologies or practices described in the Leaks White Paper. EPA publication relating to natural

gas STAR partners experience with DI&M at compressor stations supports all of Kinder Morgan’s

assertions and indicates that significant reduction in methane emissions can be achieved by

implementing a DI&M program at a compressor station by locating leaking components and focusing

maintenance efforts on the largest leaks that are profitable to repair.

2. Leak Thresholds and Repair

EPA should be careful about setting any specific leak thresholds or levels of leak requiring

repair in the transmission and storage sector. In many instances, repairs may be impossible without

blowing down a portion of the pipeline. As noted above, pipeline blowdowns result in significantly

greater methane emissions than leaks, compressors and pneumatics combined. As a result, EPA

should avoid requiring repair of leaks that require blowdowns. In particular, a leak should not require

repair (unless and until the next required blowdown (if any)) if the blowdown (either from the pipeline

or the compressor) is necessary to conduct the repair and would result in great methane emissions

over an annual period than emissions from the leak.

Additionally, Kinder Morgan has determined that some leaks can be repaired immediately;

however, because of the location of compressors in the transmission and storage sector, problems

with availability of equipment, availability of personnel, or other factors may result in a delay on

conducting those repairs or counsel against repair immediately.

Contrary to EPA’s statements, while some repairs may be easy, economical and

accomplished quickly, others may either be uneconomical or take considerable planning, timing, and

scheduling prior to implementation. Existing leak detection and repair regulatory programs (e.g., 40

C.F.R. Part 60, Subpart KKK, 40 C.F.R. Part 63, Subpart OOOO, and various state regulatory

programs) recognize these considerations and include provisions regarding repair timing and

deferral (e.g., at next scheduled plant turn-around). Any leak repair or reduction program would

need to address these same repair or replacement considerations, timing and scheduling

requirements.

D. Pneumatics

Gas driven pneumatic controllers at transmission and storage facilities and gas plants are

required for safety reasons. Specific pneumatic device examples include, but are not limited to,

mainline block valves, emergency shutdown valves, pipeline or station manifold isolation valves,

pressure relief valves, etc. Natural gas driven pneumatic controllers are needed to operate these

valves to assure valve operation or closure in emergency situations. Natural gas is needed for these

applications due to system reliability and safety reasons. Alternative operators driven by electricity,

solar power or other means would not provide the same level of safety or reliability. If electrical

power service at a compressor station or gas plant was lost, even for short, temporary time periods,

the valves would not be able to operate or close which could allow pressure build ups potentially

causing equipment failure, pipeline ruptures or explosions.

Kinder Morgan does not believe that any potential regulations should be proposed to control

the emissions from pneumatics in the transmission and storage industry segments. Based on

Kinder Morgan’s Subpart W monitoring data, GHG emissions from pneumatics at its compressor and

storage facilities in the transmission and storage segment reportable under Subpart W accounted for

29

EXHIBIT A

EPA Methane White Papers:

KM Responses to EPA Charge Questions
30

EPA Methane White Papers: KM Responses to EPA Charge Questions

Compressors:

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.

Kinder Morgan Energy Partners, L.P. (Kinder Morgan) respectfully directs EPA to Section

X.B.2 of Kinder Morgan’s formal comments in response to EPA’s Methane White Papers

(KM Comments). In this Section X.B.2., Kinder Morgan asserts that, in general, EPA should

await further information under development as part of the Subpart W reporting program and

through existing and soon-to-be completed studies specific to the transmission and storage

sector.

2. Did this paper appropriately characterize the different studies and data sources that

quantify vented emissions from compressors in the oil and gas sector?

Kinder Morgan respectfully directs EPA to Section X.B.2 of the KM Comments. In this

Section X.B.2., Kinder Morgan asserts that, in general, EPA should wait for further

information under development as part of the Subpart W reporting program and through

existing and soon-to-be completed studies specific to the transmission and storage sector.

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.

Kinder Morgan identifies other mitigation options in Section X.B.3.a (Alternative Technology

to Control Compressor Emissions). Specifically, Kinder Morgan recommends that EPA reevaluate the most relevant sources of emission from compressors (particularly in the

transmission and storage sector) and further evaluate practices that assist in reducing those

emissions. Such practices may include, but should not be limited to, compressor piping burn

down systems.

4. Did this paper appropriately characterize the emissions reductions achievable from the

emissions mitigation technologies discussed for reciprocating compressors and wet seal

centrifugal compressors?

Kinder Morgan incorporates American Petroleum Institute (API) and Interstate Natural Gas

Association of America (INGAA) comments by reference. See also Section X.B.2.d for

discussion of emissions from wet seal centrifugal compressors versus dry seal centrifugal

compressors. In this Section X.B.2.d, Kinder Morgan provides actual measured data

collected over the last three years in order to supplement EPA’s access to known datasets

and provide insight and direction on the emissions associated with reciprocating and
31

centrifugal compressors and the sources that have the potential for the greatest level of

methane reduction while thoroughly considering any technical obstacles that could prevent

achieving those reductions. Kinder Morgan’s data shows significant differences in many

areas from those emissions estimates provided by EPA in its white paper.

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?

Kinder Morgan respectfully directs EPA to Sections X.B.3.a (Economic Evaluation for

Reciprocating Compressors) and X.B.3.b (for Centrifugal Compressors) of the KM

Comments. At Section X.B.3.a, Kinder Morgan suggests improvements to EPA’s cost and

cost-benefit analyses of technologies for reciprocating compressors to fully account for all

costs related to the proposed technologies. At Section X.B.3.b, Kinder Morgan suggests

improvements to EPA’s cost and cost-benefit analyses of technologies for centrifugal

compressors based upon information received by Kinder Morgan from vendors of commonly

owned compressors.

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.

Kinder Morgan identifies other mitigation options in Section X.B.3.a (Alternative Technology

to Control Compressor Emissions). Furthermore, Kinder Morgan has identified other

sources that have greater emissions than those proposed by EPA for mitigation at Section

X.B.2.d of the KM Comments.

7. Are there technical limitations that make the replacement of wet seals with dry seals

impractical at certain existing centrifugal compressors?

Kinder Morgan respectfully directs EPA to Section X.B.3.b of the KM Comments. In this

Section X.B.3.b Kinder Morgan describes the limitations of the replacement of wet seals with

dry seals and why any wet seal replacement policy or requirement would need to address

manufacturer and other qualified vendor capabilities, parts and material supply, delivery

schedules, and impacts to national gas supply and transportation capabilities.

8. Are there technical reasons why an operator would use a wet seal centrifugal compressor

without a gas recovery system?

Simply stated, the methane emission reductions for the transmission and storage sector are

not as significant as thought by the EPA. Kinder Morgan respectfully directs EPA to Section

X.B.3.b of the KM Comments (as described in Response to Question No. 7, above).

9. Are there technical limitations that make the installation of gas capture systems at certain

reciprocating compressors impractical?
32

Yes. Kinder Morgan respectfully directs EPA to Section X.B.3.a of the KM Comments, which

discusses other mitigation options (Alternative Technology to Control Compressor

Emissions).

10. Please comment on the prevalence of the different emission mitigation options in the

field.

Kinder Morgan is not aware that any of the emission mitigation options are prevalent in the

field. Kinder Morgan has only replaced one wet seal with a dry seal and does not operate

any control systems to control venting from its rod packing or wet seal devices at this time.

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?

As discussed in Section X.B.2.d (providing actual measured data collected over the last

three years), Kinder Morgan’s data does not indicate that dry seal systems have substantial

benefits from an emission perspective over wet seal systems.

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?

Kinder Morgan incorporates API and INGAA comments by reference. Kinder Morgan also

respectfully directs EPA to Section X.A of the KM Comments, which outlines specific

concerns noted by API and INGAA and shared by Kinder Morgan, including ongoing studies

by Colorado State University and the Pipeline Research Council International.

* * *

Leaks:

1. Did this paper appropriately characterize the different studies and data sources that

quantify VOC and methane emissions from leaks in the oil and natural gas sector?

Kinder Morgan incorporates API and INGAA comments by reference.

2. Please comment on the approaches for quantifying emissions and on the emission

factors used in the data sources discussed. Please comment on the national estimates of

emissions and emission factors for equipment leaks presented in this paper. Please

comment on the activity data used to calculate these emissions, both on the total national

and regional equipment counts.

Kinder Morgan respectfully directs EPA to Section X.B.2 of the KM Comments for a

discussion of use of the greenhouse gas reporting program data versus concerns with

emissions factors utilized and relied upon by EPA in its technical white paper, including the

Compressor White Paper and the Leak White Paper.
33

3. Are the emission estimating procedures and leak detection methods presented here

equally applicable to both oil and gas production, processing, and transmission and

storage sector?

No. Kinder Morgan respectfully directs EPA to Section X.C. and X.C.1 of the KM Comments

for a discussion of the differences in part between the transmission and storage sector and

other portions of the natural gas sector.

4. Are there ongoing or planned studies that will substantially improve the current

understanding of VOC and methane emissions from leaks and available techniques for

detecting those leaks? Please list the additional studies you are aware of.

Kinder Morgan respectfully directs EPA to Section X.A of the KM Comments, which

discusses the ongoing study of leaks from the transmission and storage sector involving

Colorado State University, Environmental Defense Fund, and multiple operators in the

transmission and storage sector (including Kinder Morgan). That study is expected to be

issued in the second half of 2014.

5. Are there types of wells sites, gathering and boosting stations, processing plants, and

transmission and storage stations that are more prone to leaks than others? Some

factors that could affect the potential for leaks are the number and types of equipment,

the maintenance of that equipment, and the age of the equipment, as well as factors that

relate to the local geology. Please discuss these factors and others that you believe to be

important.

Kinder Morgan respectfully directs EPA to Section X.C.1 of the KM Comments, which

indicates that the majority of emissions come from a small number of sources. As noted in

Section X.C.1.d, this counsels for development of a directed inspection and maintenance

program in lieu of a mandated leak detection and repair program for all components or

potential sources. Kinder Morgan incorporates API and INGAA comments by reference in

response to the remainder of this question.

6. Did this paper capture the full range of technologies available to identify leaks at oil and

natural gas facilities?

Kinder Morgan incorporates API and INGAA comments by reference.

7. Please comment on the pros and cons of the different leak detection technologies. Please

discuss efficacy, cost and feasibility for various applications.

Kinder Morgan incorporates API and INGAA comments by reference.

8. Please comment on the prevalence of the use of the different leak detection technologies

at oil and gas facilities. Which technologies are the most commonly used? Does the type

of facility (e.g., well site versus gathering and boosting station) affect which leak

detection technology is used?
34

Kinder Morgan incorporates API and INGAA comments by reference.

9. Please provide information on current frequencies of revisit of existing voluntary leak

detection programs in industry and how the costs and emission reductions achieved vary

with different frequencies of revisit.

Kinder Morgan incorporates API and INGAA comments by reference.

10. Please comment on the potential for using ambient/mobile monitoring technologies in

conjunction with OGI technology. This would be a two-phase approach where the

ambient/mobile monitoring technology is used to detect the presence of a leak and the

OGI technology is used to identify the leaking component. Please discuss efficacy, cost

and feasibility.

Kinder Morgan incorporates API and INGAA comments by reference.

11. Please comment on the cost of detecting a leak when compared to the cost to repair a

leak. Multiple studies described in this paper suggest that detecting leaks is far more

costly than repairing leaks and, due to generally low costs of repair and the subsequent

product recovery, it is almost always economical to repair leaks once they are found.

Please comment on this overall conclusion.

Kinder Morgan respectfully directs EPA to Section X.C.2 of the KM Comments, which

demonstrate that it is not correct to conclude that repair is almost always economical to

repair leaks once found. In the transmission and storage sector it can be very important to

quantify emissions from leaks because in some circumstances, namely those where repair

requires blowdown of the pipeline or similar venting, the emissions resulting from the repair

may far exceed the emissions from the leaking equipment in the first instance.

Kinder Morgan further incorporates by reference API and INGAA comments.

12. If the conclusion is correct that it is almost always economical to repair leaks once they

are found, then how important is the quantification of emissions from leaks when

implementing a program to detect and repair leaks?

Kinder Morgan respectfully directs EPA to Section X.C.2 of the KM Comments, which

demonstrate that it is not correct to conclude that repair is almost always economical to

repair leaks once found. In the transmission and storage sector it can be very important to

quantify emissions from leaks because in some circumstances, namely, those where repair

requires blowdown of the pipeline or similar venting, the emission resulting from the repair

may far exceed the emissions from the leaking equipment in the first instance.

13. Please comment on the state of innovation in leak detection technologies. Are there new

technologies under development that are not discussed in this paper? Are there

significant advancements being made in the technologies that are not described in this

paper?

Kinder Morgan incorporates API and INGAA comments by reference.
35

* * *

Pneumatics:

1. Did this paper appropriately characterize the different studies and data sources that

quantify emissions from pneumatic controllers and pneumatic pumps in the oil and gas

sector?

Kinder Morgan incorporates API and INGAA comments by reference.

2. Please discuss explanations for the wide range of emission rates that have been

observed in direct measurement studies of pneumatic controller emissions (e.g., Allen et

al., 2013 and Prasino 2013). Are these differences driven purely by the design of the

monitored controllers or are there operational characteristics, such as supply pressure,

that play a crucial role in determining emissions?

Kinder Morgan incorporates API and INGAA comments by reference.

3. Did this paper capture the full range of technologies available to reduce emissions from

pneumatic controllers and pneumatic pumps oil and gas facilities?

Kinder Morgan incorporates API and INGAA comments by reference.

4. Please comment on the pros and cons of the different emission reduction technologies.

Please discuss efficacy, cost and feasibility for both new and existing pneumatics.

Kinder Morgan agrees with the Pneumatic White Paper that replacing a high bleed

pneumatic with low bleed controllers is infeasible in situations where a process condition

may require a fast or precise control response so that it does not stray too far from the

desired set point. A slower-acting controller could potentially result in damage to equipment

and/or become a safety issue.

5. Please comment on the prevalence of the different emission control technologies and the

different types of pneumatics in the field. What particular activities require high bleed

pneumatic controllers and how prevalent are they in the field?

Kinder Morgan data does not show use of a significant number of pneumatic devices at

Kinder Morgan’s compressor and storage facilities. In fact, based on Kinder Morgan’s

Subpart W monitoring data, GHG emissions from pneumatics at its compressor and storage

facilities accounted for approximately 1% of the total GHG emissions reported by Kinder

Morgan to EPA under Subpart W. This statistic supports Kinder Morgan’s understanding

that pneumatics are a very small source within the transmission and storage sector.

6. What are the barriers to installing instrument air systems for converting natural gasdriven pneumatic pumps and pneumatic controllers to air-driven pumps and controllers?

Kinder Morgan incorporates API and INGAA comments by reference.
36

7. Are there situations where it may be infeasible to use air driven pumps and controllers in

place of natural gas-driven pumps and controllers even where it is feasible to install an

instrument air system?

Kinder Morgan incorporates API and INGAA comments by reference.

8. Did this paper correctly characterize the limitations of electric-powered pneumatic

controllers and pneumatic pumps? Are these electric devices applicable to a broader

range of the oil and gas sector than this paper suggests?

Kinder Morgan incorporates API and INGAA comments by reference.

9. Are there ongoing or planned studies that will substantially improve the current

understanding of VOC and methane emissions from pneumatic controllers and pneumatic

pumps and available techniques for increased product recovery and emissions

reductions?

Kinder Morgan incorporates API and INGAA comments by reference.