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/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM 

TO: Bruce Moore, EPA/OAQPS/SPPD/CCG

FROM: Bradley Nelson, EC/R, Inc.

DATE: October 18, 2011

SUBJECT: Summary of the October 6, 2011, Teleconference with the Sierra Club and the 

U.S. Environmental Protection Agency to Discuss the Proposed Oil & Gas 

NSPS/NESHAP

I. INTRODUCTION

The Sierra Club requested this meeting with EPA to discuss questions on the proposed Oil and 

Gas NSPS (40 CFR Part 60, subparts KKK, LLL, and OOOO) and NESHAP (40 CFR Part 63, 

subpart HH and HHH). This meeting summary will be available in the docket for this 

rulemaking (Docket ID No. EPA-HQ-OAR-2010-0505). The proposed rule for the oil and 

natural gas sector was published in the Federal Register on August 23, 2011 (76 FR 52738). 

II. ATTENDEES

U.S. Environmental Protection Agency

Bruce Moore

Greg Nizich

Alex Macpherson

Sierra Club

Craig Segall

Bruce Buckheit

Darin Schroeder

Ranajit Sahu

Praveen Amar

David McCabe

Robin Cooley

Cindy Copeland

Nathan Matthews
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EC/R Incorporated

Heather Brown

Denise Grubert

Bradley Nelson 

III. SUMMARY OF DISCUSSION

Craig Segall opened the meeting by stating that the purpose of the call was to understand the 

decisions that were made by EPA on the proposed rules, and to discuss how these rules will be 

enforced. He further stated that this is an important rule to reduce methane fugitive emissions. 

Bruce Moore stated that the proposed rules are currently still in the comment period and EPA 

could answer questions and provide clarifications, but could not provide any responses to 

comments on the proposed rules. 

The first question that was asked by the Sierra Club was why EPA decided in the proposed rules 

to control volatile organic compounds (VOC) emissions rather than methane. EPA stated that 

they believe that many of the proposed requirements for control of VOC emissions that were 

determined to be cost effective also control methane emissions. The Sierra Club asked if there 

were technical reasons why VOC was being used for the proposed rule. A member of the Sierra

Club group suggested that EPA require a leak definition based on total hydrocarbons rather than 

VOC. EPA asked the group to provide comment on the types of analyzers that measure 

hydrocarbons from equipment leaks.

The Sierra Club asked if there was a VOC cost per ton threshold that determined which control 

options were cost effective. EPA responded that this rule was an ozone driven regulation and 

each control option was evaluated separately. EPA further stated that there was no set cost per 

ton threshold that determined if a control option was costs effective. A Sierra Club member 

stated if methane was included that more control options may have been determined to be cost 

effective. Another Sierra Club member asked what is the reactivity of methane. EPA responded 

by acknowledging that methane is an ozone producer, but EPA has not developed any 

quantitative studies related to methane cost effectiveness as a precursor to ozone. 

The next question asked by the Sierra Club was regarding the scope of source coverage in 

section 111(d) for VOC from centrifugal compressors. EPA stated that based on information 

from the Natural Gas STAR, the replacement of wet seals with dry seals is common industry 

practice. The Sierra Club asked if flares could be used to control emission from wet seals. EPA 

responded that they requested comment from industry on situations where wet seals would be 

required for centrifugal compressors. 
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A Sierra Club member asked what was the timing basis for the rod packing replacement for 

reciprocating engines. EPA responded that based on information from Natural Gas STAR the 

replacement period was between 3 to 5 years. Therefore, EPA used 26,000 hours as the basis for 

rod packing replacement which is just under 3 years of operating time. Another member asked if 

leak detection and repair (LDAR) procedures could be used for reciprocating engines. EPA 

responded there are some issues with using an LDAR approach to measure emissions from rod 

packing due to back pressure. EPA further stated that they requested comment on setting of 

thresholds for individual compressors. A Sierra Club asked if optical LDAR or other techniques 

would work for detecting leaks from reciprocating compressor rod packing. EPA stated that 

leaks occur from all compressor rod packing; therefore the optical imaging equipment would 

always see leaks from compressor rod packing. Monitoring for pressure drop in the compressed 

gas would also not find leaks because there is no noticeable pressure drop when the leak 

increases.

The Sierra Club asked about the requirements for existing wells, specifically if recompletions 

were considered to be modifications. The group also asked if refracking an existing well would 

be considered a modification. A member of the group believes that the industry will state the 

there is no emission change when a well is refracked. EPA answered that the proposed rule is 

based on the §60.2 definition of modification, which includes a capital expenditure requirement 

of 10 percent of the original cost for the well. Because of this definition, EPA does not expect 

existing wells to become new sources. A member of the Sierra Club stated that capital 

expenditures should not apply for these existing wells. EPA suggested that they include this 

issue in their comments.

A Sierra Club member suggested that high bleed controllers should not be allowed under this 

rule and asked if EPA had information or data on the equipment life of these units. EPA replied 

that they did not have any data with respect to the equipment life of high bleed controllers.

A member asked if the industry was concerned with the costs of separators and the requirements 

for reduced emissions completions (REC). EPA answered that industry is already using 

separators and that they sell the collected liquids as condensate. EPA stated that they observed 

separators on a skid that can be driven from well to well when needed. A member asked if EPA 

had emissions or cost data on produced water from these wells. EPA answered that they had no 

data on produced water and suggested the group add this issue to their comments. 

A Sierra Club member asked whether EPA looked at cases where small throughput tanks were 

located with large throughput tanks. EPA replied that that it was not cost effective to apply 

controls on tanks with throughputs less than 1 barrel per day. However, EPA stated that

emission rates were being considered as a threshold for tanks. EPA also stated that since only 
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condensate and oil tanks were specified in the proposed rule, produced water tanks could not be 

included in the final rule.

A member of the Sierra Club asked if EPA found any cost difference between controlling 

existing tanks with flares or a vapor recovery unit (VRU). EPA responded that they saw no cost 

difference between the two control options. 

The Sierra Club asked if EPA had any information on the composition of the emissions or 

control effectiveness from a pit flare or flare. EPA responded that they did not have any 

information on the emissions from either of the flares. EPA did note that a VRU could not be 

used in all applications; therefore a flare would be the only option. EPA stated that they would 

discuss this issue with the EPA Office of Research and Development (ORD). A Sierra Club 

member stated that it is difficult to measure emissions from a flare, and asked if oxidizers or 

afterburners were considered. EPA replied that the proposed rule requires the use of enclosed 

flares, which have residence time in the combustion zone and can be tested. EPA stated that the 

enclosed flare would be certified by the manufacturer to be compliant with the proposed rule and 

this would alleviate the burden of testing. A member of the Sierra Club suggested that EPA 

include an audit program requirement with the manufacturer certification to ensure that the 

emission reductions are being achieved. EPA stated that the Sierra Club should include this 

suggestion in their comments. 

The next topic that was discussed was enforcement. A Sierra Club member asked what an 

inspector needed to prove in order to show a violation. EPA recognized that some of the 

definitions are objective. A member of the Sierra Club noted that they believe the definitions 

need to be more objective, with a couple examples being “fracking” and “refracking.” The 

member also noted that “workovers” were never defined in the proposed rule. EPA replied that 

refracking requires perforating the well casing or refracturing the rock. EPA also stated the need 

to remove “workovers” from the proposed rules. EPA asked for definition suggestions for 

“high” volume and “high” pressure. A member of the Sierra Club suggested the test for 

refracking should be an engineering test or something that could be measured.

The next topic of discussion was pneumatics. A member of the Sierra Club asked what was 

meant by the term “predicated” in the requirements for pneumatic controllers. EPA stated that 

this requirement would allow the use of high bleed controllers on a case by case basis. A 

member of the Sierra Club suggested that the EPA provide a list of operations where high bleed 

controllers could be used. EPA suggested that high bleed controllers are needed for emergency 

situations.
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A Sierra Club member asked if a feasibility standard could be added to the proposed rules for 

delineated and wildcat wells that are in close proximity to the pipeline. EPA stated that they 

believed some states may already have requirements for this. 

A Sierra Club member stated that they were having difficulties finding some of the documents 

that were referenced. EPA asked the group to send a list of the documents and they would make 

them available. The Sierra Club also offered to provide assistance with issues being raised by 

industry if necessary.