Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions Subpart W 

Meeting Documentation: WCI WCI Oil & Gas Subcommittee Participants in April 15, 2010 conference call with EPA re Subpart W Name Email Affiliation Sandra Ely sandra.ely@state.nm.us New Mexico Environment 

Dept. 

Brad Musick brad.musick@state.nm.us New Mexico Environment 

Dept. 

Mike Schneider mike.schneider@state.nm.us New Mexico Environment 

Dept. 

Steve Burr burr.steven@azdeq.gov Arizona Dept. of 

Environmental Quality 

Douglas Thompson dthompson@arb.ca.gov California Air Resources 

Board 

Byard Mosher bmosher@arb.ca.gov California Air Resources 

Board 

Chad Harris cdharris@utah.gov Utah Dept. of Environmental 

Quality 

Tom Moore MooreT@cira.colostate.edu Western Governors’ 

Association 

Peggy Foran peggy@theclimateregistry.org The Climate Registry Dennis Paradine dennis.paradine@gov.bc.ca British Columbia Ministry of 

Environment 

Richard Caesar Richard.Caesar@gov.bc.ca British Columbia Ministry of 

Energy Mines and Petroleum Resources 
Date Staff Contact 

Information (Name, email, phone #) 

Name of Organization (Attach list of all attendees names and emails if possible) 

Summary of Discussion (e.g., applicability, reporting requirements, etc.) 

Written CommeProvideDid they also subto Dock

Roger Fernandez Akachi Imegwu 

See following pages See Below 

WCI Oil & Gas Subcommittee Questions for Roger Fernandez, EPA Onshore Production Reporting by Basin and Jurisdiction

The proposed Subpart W calls for aggregation of onshore production sources by ownership withibasins as defined by AAPG cross state lines. EPA has stated their intention not to preempt state programs. “EPA agrees that State and regional programs are crucial to achieving emissions redu

rule does not preempt any other programs” (MRR Preamble, FR 74:209, p. 56266). For state repit would be necessary to obtain data from onshore production sources by basins within the state p
jurisdiction rather than only basin-wide. To avoid preemption of state reporting of onshore p

emissions, would EPA consider designing the reporting tool to accommodate inputs of state

as a subtotal, in addition to the grand total of basin-wide emissions by the owner or operato

Optional Higher-Tier Emissions Quantification Methods

For emissions reporting to support state and regional cap and trade programs, quantification meththan those proposed will be required for many source types. Will EPA consider adding option

methods to Subpart W?Field Gas Combustion

Field gas combustion is a significant source of emissions in the onshore production segment. Thcomposition of field gas and the dispersed distribution of some combustion devices in onshore prlead us to believe that special requirements may be needed for estimated field gas fuel consumpt

composition. Although EPA may provide further clarification on the definition of “pipeline qualreferenced in Subpart C, we doubt whether the special requirements necessary for field will be in

Subpart. Will EPA consider adding field gas combustion as a source type in Subpart W or m

addressed in Subpart C (perhaps in a later revision)?

Dividing Point Between Gas Production and Processing

Gathering systems or stations are mentioned in the source category definitions for both “onshore 

natural gas production” and “onshore natural gas processing plants” [§98.230(a)]. Where is the 

between gas production and processing? Stand-by compressor GHG emissions

Why does EPA propose to separate these emissions (Page 85)? Definitions

Please consider modifying the acid gas definition to reflect that acid gas “means hydrogen sulfid

carbon dioxide ... acid gas removal.” The sweet gas definition reflects this distinction (i.e. and/oappropriate for CBM as it typically does not include H2S. 
Please consider adding a scrubber tank dump valve definition (Page 45 preamble)? What are the

does EPA propose to verify their presence at any given O/G site? State Operating Permits

Please clarify the types of permits covered by this reference (Page 35 preamble). Dehydrators

Why are dehydrator GHG emissions not counted for compressor stations in the natural gas transm

Table 1 of the proposed rule description document)? Acid Gas Removal requirements

Did EPA consider requiring AGR’s subject to SO2 CEMS requirements to add CO2 CEMS or is 

analyzer described in 98.233(d)(1) essentially a CO2 CEMS? 

Methane Emissions from AGR Units

Why has EPA decided not to require calculation of methane emissions from AGR units? 
API / EPA Meeting 

USEPA OAR Offices, 1310 L Street, Washington DC 

April 20, 2010 3:00 pm EDT 

List of Issues Discussed

Subpart W

1. EPA should reconsider the large number of wells included in subpart W 

2. EPA’s cost for subpart W is too low 3. EPA should consider a phased in approach due to the large number of wells 

4. EPA should consider simpler methods, less cost, balanced against amount of emissions 

5. EPA should consider population averages at basin/sub basin level 

6. EPA should consider small exclusion for compressors, heaters, low bleed pneumatics 

7. EPA should consider the difficulty of reporting emissions for leased, rented, and contracte

Subpart RR

1. EPA should consider an opt-in provision if sequestration 2. EPA should recognize that confidentiality, including their process, is important 

3. EPA should consider that CO2 for EOR is a production technique not for sequestration