**6101 Holiday Hill Road Midland, TX 79707**  **( 432**  **) 687 -**  **1777 jimmyc@forl.com**  **Jimmy D. Carlile HSE and Regulatory Supervisor**  June 16, 2014 Mr. Roberto Morales US Environm ental Protection Agency Office of Air Quality

Planning and Standards Mail Code: C40 4
- 02 109 T.W . Alexander Drive Research Triangle Park, NC 27711 Dear Mr. Morales, Re: EPA’s Oil and Gas Methane W hite Papers The Permian Basin Petroleum Association (PBPA) represents over 1,000 member companies engaged in all aspects of environmentally responsible exploration and production of oil and natural gas in the Permian Basin Region of W est Texas and Southeast New Mexico. The Permian Basin is the most prolific oil producing region in the United States and produces approximately 20% of the oil prod uced annually in Am erica

. PBPA’s m ission is to provide safety

education, legislative and regulatory engagem ent, and support services for the petroleum industry to promote member effectiveness. On behalf of the PBPA, I am providing the following comments. The EPA W hite P aper studies make reference to the measured methane drop in the atmosphere between 1990 and 2011 , and then claim that a **projected increase** is justification for the new reduction strategies. Assumptions that methane concentrations will rise is premature and has no basis in science and fact

. Additionally

the white papers fail to take into consideration the reductions obtained through the recent NSPS Subpart OOOO rules. According to the EPA, the reductions in greenhouse gas from these Subpart OOOO rules were expected to be substantial by themselves. Many

of the Subpart OOOO rules were implemented despite the absence of proven economic viability as is required under NSPS. It is premature to issue additional rules without allowing m ore time t o evaluate the effect, in both emission reduction and cost to industry , before proposing additional burdensome regulations. The W hite Papers contained a small sample size, tended to make generalizations , and were originally intended to measure VOC emissio ns and HAPS. That data is now being used for the purpose of methane studies and pre sumably , to justify

additional policy

making. PBPA would prefer to see a thorough study carried out in a ma nner similar to the Hydraulic Fracturing Study . In that s tudy a Quality

Management Plan and Quality Assurance Project Plan were developed. The studies and data used for the W hite Papers failed to meet these criteria. The following are paper specific comments: • Compressors
- Based upon the 2012 EPA inventory of GHG em issions, 86,259 tonnes originated from the production segment, 724,295 tonnes originated from gas processing, and 1.261 million tonnes originated from the transmission & storage segment. Because the production segment represents a small portion of emiss ions relative to the processing and transmission & storage segment, additional regulations for that segment areunwarranted. The EPA estimates in Table 4
- 1 that individual com pressor emission reductions at production

locations would only

be reduce d by

0.158 tons/compressor
- ye ar for methane and 0.0439 tons/compressor
- ye ar for VOC. These reductions are only a fraction of the next largest segment (gathering and boosting). The effects of em issions reduction caused by S ubpart OOOO should be more thoroughly evaluated. • Completions and production from hydraulically fractured oil wells
- The EPA states in its introduction the need to “obtain a clear and accurate understanding of emerging data on air emissions and available mitigation options”. The EPA acknowledges that its informa tion regarding fractured oil well com pletions and recompletions is limited. It also states that Reduced
- Em ission Completions (RECs) can be effective in “some oil wells producing associated gas”. The EPA does not attempt to di fferentiate which oil wells would m ost effectively utilize RECs, but instead appears to lump
- sum categorize oil wells together. EPA proposed alternatives to flaring captured gas such as conversion to LNG, CNG, gas reinjection and electricity generation ar e extremely im practical in the Permian Basin. It is expected that these alternative technologies would be impractical in other parts of the United States as well. • Leaks
- Leaks represent lost revenue to the oil and gas industry and are addressed large ly as a matter of economics. L eak Detection and Repair programs were developed for gas processing plants and are labor intensive. Leaks discovered in the up
- stream segment are relatively negligible com pared to gas processing plants where LDAR programs wer e designed to occur. The application of LDAR programs to the upstream segment is unwarranted. The current Subpart OOOO requirements already address leaks , as do current state permitting programs. • Liquids unloading
- The EPA’s GHG inventory has conclu ded that liquid unloading from gas wells accounted for 14% of all emissions from gas production and usually occur at a small percentage of wells. The Wh ite P aper states that costs associated with addressing leaks is largely related to labor required to lo cate them. Because these leaks tend to occur at only a small percentage of wells it would seem logical that the vast percentage of labor required to locate them would be unfruitful and unwarranted. • Pneum atic devices
- The EPA states that 13% of overal l m ethane emissions originate from pneumatic
controllers. The white paper makes no reference to projected reductions achieved by S ubpart OOOO. Nor does the paper seem to acknowledge that high
- bleed pneum atics will eventually be phased out entirely . Additi onal regulation in regards to pneumatics, beyond those requirements in Subpart OOOO , are unjustified. If y ou have any

questions or comments concerning PBPA’s comments, please feel free to contact me at the letterhead address, phone number or email addre ss. Yours truly , 

# Jimmy D. Carlile Jimmy D. Carlile HSE and Regulatory

Supervisor **Chairman –**  **P ermian Basin Petroleum A**  **ssociation Regulatory Practices Committee**