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 Environmental Protection Agency

Office of Air Quality Planning and Standards 

Mail Code: C404-02

109 T.W. Alexander Drive

Research Triangle Park, NC 27711

Dear Mr. Morales,

Re: EPA’s Oil and Gas Methane White 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 West 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 produced annually in America. PBPA’s mission is 

to provide safety education, legislative and regulatory engagement, and support services for the petroleum 

industry to promote member effectiveness. On behalf of the PBPA, I am providing the following comments.

The EPA White Paper 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 more time to evaluate the effect, in both emission reduction and cost to industry, before 

proposing additional burdensome regulations.

The White Papers contained a small sample size, tended to make generalizations, and were originally intended 

to measure VOC emissions and HAPS. That data is now being used for the purpose of methane studies and 

presumably, to justify additional policy making. PBPA would prefer to see a thorough study carried out in a 

manner similar to the Hydraulic Fracturing Study. In that study a Quality Management Plan and Quality

Assurance Project Plan were developed. The studies and data used for the White Papers failed to meet these 

criteria. 

The following are paper specific comments:

• Compressors- Based upon the 2012 EPA inventory of GHG emissions, 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 emissions 

relative to the processing and transmission & storage segment, additional regulations for that segment are 
unwarranted. The EPA estimates in Table 4-1 that individual compressor emission reductions at production 

locations would only be reduced by 0.158 tons/compressor-year for methane and 0.0439 tons/compressor-year 

for VOC. These reductions are only a fraction of the next largest segment (gathering and boosting). The effects 

of emissions reduction caused by Subpart 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 information regarding fractured oil well completions and recompletions is limited. 

It also states that Reduced-Emission Completions (RECs) can be effective in “some oil wells producing 

associated gas”. The EPA does not attempt to differentiate which oil wells would most 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 are extremely impractical 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 largely as a matter of 

economics. Leak Detection and Repair programs were developed for gas processing plants and are labor 

intensive. Leaks discovered in the up-stream segment are relatively negligible compared to gas processing 

plants where LDAR programs were 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 concluded 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 White Paper 

states that costs associated with addressing leaks is largely related to labor required to locate 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. 

• Pneumatic devices- The EPA states that 13% of overall methane emissions originate from pneumaticcontrollers. The white paper makes no reference to projected reductions achieved by Subpart OOOO. Nor does 

the paper seem to acknowledge that high-bleed pneumatics will eventually be phased out entirely. Additional 

regulation in regards to pneumatics, beyond those requirements in Subpart OOOO, are unjustified. 

If you have any questions or comments concerning PBPA’s comments, please feel free to contact me at the 

letterhead address, phone number or email address.

Yours truly,

Jimmy D. Carlile

Jimmy D. Carlile

HSE and Regulatory Supervisor

Chairman – Permian Basin Petroleum Association

 Regulatory Practices Committee