Proposed Rule: Mandatory Reporting ofGreenhouse Gas Emissions Subpart WMeeting Documentation: WCIWCI Oil & Gas SubcommitteeParticipants in April 15, 2010 conference call with EPA re Subpart WName Email AffiliationSandra Ely sandra.ely@state.nm.us New Mexico EnvironmentDept.Brad Musick brad.musick@state.nm.us New Mexico EnvironmentDept.Mike Schneider mike.schneider@state.nm.us New Mexico EnvironmentDept.Steve Burr burr.steven@azdeq.gov Arizona Dept. ofEnvironmental QualityDouglas Thompson dthompson@arb.ca.gov California Air ResourcesBoardByard Mosher bmosher@arb.ca.gov California Air ResourcesBoardChad Harris cdharris@utah.gov Utah Dept. of EnvironmentalQualityTom Moore MooreT@cira.colostate.edu Western Governors’AssociationPeggy Foran peggy@theclimateregistry.org The Climate RegistryDennis Paradine dennis.paradine@gov.bc.ca British Columbia Ministry ofEnvironmentRichard Caesar Richard.Caesar@gov.bc.ca British Columbia Ministry ofEnergy Mines and PetroleumResourcesDate Staff ContactInformation (Name,email, phone #)Name ofOrganization(Attach list of allattendees namesand emails ifpossible)Summary of Discussion (e.g., applicability,reporting requirements, etc.)WrittenCommentsProvided?Did theyalso submitto Docket?Date sent toEPA- CCDRoger FernandezAkachi ImegwuSee following pages See BelowWCI Oil & Gas Subcommittee Questions for Roger Fernandez, EPAOnshore Production Reporting by Basin and JurisdictionThe proposed Subpart W calls for aggregation of onshore production sourcesby ownership within basins, butbasins as defined by AAPG cross state lines. EPA has stated their intention not to preempt state or regionalprograms. “EPA agrees that State and regional programs are crucial to achieving emissions reductions, and thisrule does not preempt any other programs” (MRR Preamble, FR 74:209, p. 56266). For state reporting programs,it would be necessary to obtain datafrom onshore production sources by basins within the state program’sjurisdiction rather than only basin-wide.To avoid preemption of state reporting of onshore productionemissions, would EPA consider designing the reporting tool to accommodate inputs of state-level emissionsas a subtotal, in addition to the grand total ofbasin-wide emissions by the owner or operator?Optional Higher-Tier Emissions Quantification MethodsFor emissions reporting to support state and regional cap and trade programs, quantification methods more accuratethan those proposed will be required for many source types.Will EPA consider addingoptional higher tiermethods to Subpart W?Field Gas CombustionField gas combustion is a significant source of emissionsin the onshore productionsegment. The variablecomposition of field gas and the dispersed distributionof some combustion devices in onshore production basinlead us to believe that special requirements may be needed for estimated field gas fuel consumption andcomposition. Although EPA may provide further clarification on the definition of “pipeline quality” gas asreferenced in Subpart C, we doubt whether the special requirements necessaryfor field will be included in thatSubpart.Will EPA consider adding field gas combustion asa source type in Subpart W or must this beaddressed in Subpart C (perhaps in a later revision)?Dividing Point Between Gas Production and ProcessingGathering systems or stations are mentioned in the source category definitions forboth “onshore petroleum andnatural gas production” and“onshore natural gas processing plants” [§98.230(a)].Where is the dividing pointbetween gas production and processing?Stand-by compressor GHG emissionsWhy does EPA propose to separate these emissions (Page 85)?DefinitionsPlease consider modifying the acid gas definition toreflect that acid gas “means hydrogen sulfide (H2S) and/orcarbon dioxide ... acid gas removal.” The sweet gas definition reflects this distinction (i.e. and/or) and isappropriate for CBM as it typically does not include H2S.Please consider adding a scrubber tank dump valve definition (Page 45 preamble)?What are these valves and howdoes EPA propose to verify theirpresence at any given O/G site?State Operating PermitsPlease clarify the types of permits covered by this reference (Page 35 preamble).DehydratorsWhy are dehydrator GHG emissions not counted for compressor stations in thenatural gas transmission sector (SeeTable 1 of the proposed rule description document)?Acid Gas Removal requirementsDid EPA consider requiring AGR’s subject to SO2CEMS requirements to add CO2CEMS or is the continuous gasanalyzer described in 98.233(d)(1) essentially a CO2CEMS?Methane Emissions from AGR UnitsWhy has EPA decided not to require calculation of methane emissions from AGR units?API / EPA MeetingUSEPA OAR Offices, 1310L Street, Washington DCApril 20, 2010 3:00 pm EDTList of Issues DiscussedSubpart W1.EPA should reconsider the large numberof wells included in subpart W2.EPA’s cost for subpart W is too low3.EPA should consider a phased in approach due to the large number of wells4.EPA should consider simpler methods, less cost, balanced against amount of emissions5.EPA should consider population averages at basin/sub basin level6.EPA should consider small exclusion for compressors, heaters, low bleed pneumatics7.EPA should consider the difficulty of reporting emissions for leased, rented, and contracted equipmentSubpart RR1.EPA should consider an opt-in provision if sequestration2.EPA should recognize that confidentiality,including their process, is important3.EPA should consider that CO2 for EOR isa production technique not for sequestration