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 and 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 comments on the EPA technical 

white papers on VOC and Methane leak sources, released April 15, 2014. 

Linde North America is an industrial gas and engineering 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 gases include cryogenic and non-cryogenic 

nitrogen, CO2, hydrogen, oxygen, helium, argon, and liquefied natural gas (LNG). Linde is 

committed to a sustainable future and to making significant investments in alternative fuels, 

carbon sequestration, and other clean energy solutions. Among other activities, Linde continues 

to focus on and develop engineering solutions for commercially viable low- and no-water 

hydraulic fracturing and innovative carbon capture technologies. 

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 investigating the 

possible climate impacts of an inefficient natural gas delivery system and for beginning to scope 
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2 

out methods for improvement. Should EPA prepare a rulemaking on methane leaks and flaring, 

we also recommend that Linde’s technology solutions should 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 gas 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 flaring. 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 quality 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 rulemaking 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 operations, 

oil and gas transportation, and oil and gas transfer operations all result in emission of volatile 

organic compounds (VOCs). Linde North America offers a VOC controls technology called 

Cirrus that uses cryocondensation to minimize the release of VOC emissions by separating them 

from the emissions stream. Cryocondensation abatement uses cooling energy supplied by liquid 

nitrogen through a cold gas technology to efficiently condense 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, which 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 did not 

specifically make note of cryocondensation as an available control technology for VOCs, 

but this technology is commercially available and economically viable today. In the event of 

a new EPA rulemaking on VOC emissions, we recommend that Linde’s Cirrus technology be 

eligible to help oil and gas companies comply with minimum performance standards. 

By classifying a wide variety of “control” technologies 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. Such a technology-neutral approach 

could be similar to the compliance model for EPA’s newly proposed New Source Performance 

Standards (NSPS) for carbon emissions. EPA does not prescribe specific control technologies 

with this NSPS proposal; instead, individual CO2 sources can pursue a number of pathways to 
Linde comments on Methane White Papers 

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achieve the minimum performance standards. We believe Linde’s MGCU and Cirrus 

technologies could be two of many potentially acceptable pathways to measurable improvements 

in methane and VOC performance at the wellhead and along the natural gas supply chain. 

We look forward to working with EPA on these issues going forward. 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