Linde North America

575 Mountain Avenue Murray Hill, NJ 07974

June 13, 2014

Submitted To: Steve Page, Director Office of Air Quality Planning and Standards

Office of Air and Radiation U.S. Environmental Protection Agency Oilandgas.whitepapers@epa.gov

Re: Comments on White Papers on Methane and VOC Emissions in the Oil an d Natural Gas

Sector

Submitted by:

Linde North America

575 Mountain Ave Murray Hill, NJ 07974

Contact: Mike McGowan. Michael.mcgowan@linde.com / 908-771-1086

Dear Director Page and staff,

Linde North America appreciates the opportunity to submit co mments on the EPA technical white papers on VOC and Methane leak sources, released April 15, 2014.

Linde North America is an industrial gas and engineeri ng company headquartered in Murray Hill, New Jersey and is a subsidiary of The Linde Group . Linde has about 17,000 employees in the United States. We produce and distribute bulk gases for a broad variety of industrial, transportation, food and medical applications. These gase s include cryogenic and non-cryogenic nitrogen, CO 2 , hydrogen, oxygen, helium, argon, and liquefied natural gas (L NG). Linde is committed to a sustainable future and to making significant i nvestments in alternative fuels, carbon sequestration, and other clean energy solutions. Among other activities, Linde continues to focus on and develop engineering solutions for commercia lly viable low- and no-water hydraulic fracturing and innovative carbon capture technologie s.

Linde North America offers technologies that can reduce the lifecycle climate impact of the natural gas supply chain. We commend EPA and the Administration for investigat ing the possible climate impacts of an inefficient natural gas del ivery system and for beginning to scopeLinde comments on Methane White Papers

2

out methods for improvement. Should EPA prepare a rulemaki ng on methane leaks and flaring, we also recommend that Linde’s technology solutions sho uld be eligible as compliance pathways.

Comments

Regarding Reduced Emissions Completions for Methane: In the white paper on Emissions from hydraulically fractured oil wells, EPA identifies reduced emissions completions (REC) as one potential control technology for methane emissions at the wellhead. Linde offers one type of technology to assist with REC during energized fracturing, a mobile gas clean up unit (MGCU) that utilizes membrane separation to recover valuable ga s and condensate at the wellhead and prepares it for beneficial reuse or normal sale. Linde’ s technology can be applied at fractured gas wells to recover a greater amount of methane and reduce fl aring. The MGCU uses a patented membrane to separate well flowback into its constituent parts of methane and carbon dioxiderich permeate, allowing the methane to meet pipeline qualit y specifications. This unit is designed to process up to four million standard cubic feet/day (MMSCFD ) using a single skid deployed on

a standard trailer truck bed. Linde will “debut” its mobile gas clean up unit at a site in South Texas over the coming weeks.

EPA has cited similar technologies through the Natural Gas STAR Energy Partners Program as an effective pathway for reducing methane emissions (and therefore greenhouse forcing) across the natural gas supply chain. In the event of an EPA rul emaking on methane leaks, we recommend that Linde’s MGCU and other REC technologies be eligible to help gas producers comply with minimum performance standards.

Regarding VOC emissions: In its white papers, EPA has recognized that terminal opera tions, oil and gas transportation, and oil and gas transfer opera tions all result in emission of volatile organic compounds (VOCs). Linde North America offers a V OC controls technology called Cirrus that uses cryocondensation to minimize the relea se of VOC emissions by separating them from the emissions stream. Cryocondensation abatemen t uses cooling energy supplied by liquid nitrogen through a cold gas technology to efficiently conde nse VOCs from the process stream. This makes it possible to separate and contain the VOCs. In order to separate VOCs from the emissions stream, very low temperatures are needed, whic h is difficult for mechanical refrigeration to achieve. Linde’s Cirrus technology uses liquid nitrogen, a cryogen, to provide the necessary cooling. The EPA whitepapers on hydraulically fractured oil wells d id not specifically make note of cryocondensation as an available contro l technology for VOCs, but this technology is commercially available and economically viabl e today. In the event of a new EPA rulemaking on VOC emissions, we recommend th at Linde’s Cirrus technology be eligible to help oil and gas companies comply with minimu m performance standards.

By classifying a wide variety of “control” technologie s as pathways to mitigating the impacts of methane leaks, flaring, and VOC emissions, EPA can provide the natural gas supply chain with greater flexibility to achieve measurable improvements. Suc h a technology-neutral approach could be similar to the compliance model for EPA’s newl y proposed New Source Performance Standards (NSPS) for carbon emissions. EPA does not pres cribe specific control technologies with this NSPS proposal; instead, individual CO2 sources ca n pursue a number of pathways toLinde comments on Methane White Papers

3

achieve the minimum performance standards. We believe Li nde’s MGCU and Cirrus technologies could be two of many potentially acceptable pa thways to measurable improvements in methane and VOC performance at the wellhead and along t he natural gas supply chain.

We look forward to working with EPA on these issues going f orward. Thank you for your consideration and please direct any questions to Michael.Mcgowan@linde.com

.

Sincerely,

Mike McGowan

Head of Government Affairs

Linde North America