The current format implies that liquids unloading occurs for every well, which is not the case.
 `Primary technique used for liquids unloading?' should not include `Artificial lift' and `Swabbing well' in the pick list.
 The list of `Primary technique for liquids unloading' should be expanded. Techniques that should be added to the picklist include `Surfactants and foaming agents', `Installing wellhead compression', and `Combination/Other'.
 EPA's pick list for `Controls for venting of liquids unloading' incorrectly characterizes unloading operations. EPA should add `Attended venting only' as a control option for venting.
 The parameters `Year Installed (for plunger lift, velocity tubing, or other assist method)', `Total Capital Installed Cost ($)', and `Annual Operating and Maintenance Costs ($/yr in 2015)' currently require cost data for systems other than controls for manual venting. Furthermore, depending on the age of the system, much of this information will probably not be available or feasible to track down in the time allotted to answer the survey. An option needs to be provided for `Not available.'
EPA has amended Table 4 to add "Surfactants and foaming agents" to the picklist for "Primary technique used for gas well liquids unloading?"

-0068
Table 4 "Primary technique used for liquids unloading?":
 More options need to be added: foaming agents, manual plunger lift, automated (timed) plunger lift, and plunger lift with smart automation
EPA appreciates the comment and will implement as suggested.
-0068
Table 4 " Controls used for well venting for liquids unloading":
 One more option needs to be added: Knock out drum; gas recovered for use on site
EPA appreciates the comment and will implement as suggested.
-0068
Add the following questions to Table 4:
 Is the well vented or flared during testing? (vented or flared)
 What is the purpose for venting or flaring during testing, as opposed to routing to a sales line or gathering system?
 Annual number of tests
 Average time taken for unloading (hours)
 If uncontrolled, reason for no control in place
 If uncontrolled, do personnel always remain on site during venting
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Other/General

-0061
EPA should add instructions stating that `Not Applicable' should be listed if periodic testing is not required or if historical data does not exist for older and acquired wells.
Companies should provide best available data when responding to the ICR.
-0064
The Part 1 and Part 2 spreadsheets envisions a maximum of approximately 20 wells at a facility. As established above, a facility can consists of hundreds or thousands of wells. If a facility has more than the 20 wells associated with a facility, will the Part 1 and Part 2 spreadsheets be unprotected?
EPA has amended Table 2 to allow for 50 wells.  If additional rows/columns are required, facilities should contact EPA to request a larger/additional spreadsheet.
-0064
The ICR appears to include several sources that do not contribute to greenhouse gas emissions nor useful in determining potential control strategies. The EPA needs to explain why data is needed on every permanently sealed/abandoned production well. The term "permanently sealed" demonstrates that these wells are not sources of greenhouse gases.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0064
Companies inject steam and water to enhance the oil recovery process by maintaining the reservoir. The EPA should exempt water and steam injection wells from reporting as there are no methane emissions in these streams.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Should EPA choose to add storage well requirements to the "Well Sites" worksheet, then stakeholders should be allowed an additional opportunity to comment.
EPA has added the Injection-Storage Wells Tab to account for storage operations.

Tanks Separators Tab

Table 1: Facility Information

-0061, 54
The `Number of Separators at the Facility' should be removed from Table 1 Facility Information for Tanks and Separators.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Both the `Number of Atmospheric Storage Tanks <10 bbl/day at the facility' and `Number of Atmospheric Storage Tanks >=10 bbl/day' should be removed. Average hydrocarbon throughput or water throughput are already included in Table 2. General Tank / Separator Information, so these data parameters are redundant.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Sub-Section 1. Facility Information
 For number of atmospheric storage tanks with throughput greater than 10bbl/day, EPA should clarify the requirement.  40 CFR part 98 Subpart W is based on 10 bbl/day through a separator, and it is not clear if EPA's intention is that this should be the same requirement. In any case, this is a repeat of information collected in Sub-Section 2. One of the two requests should be deleted as superfluous.
 Define `water' throughput.  It is unclear if produced water falls under "hydrocarbon" or "water" throughput category.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Table 2: General Tank/Separator Information

-0046
Revise "Tank/Separator ID" to read "Tank ID." Also, the cell appears to be set to `number' in Excel and should be set to `text.' This will avoid issues with leading/trailing zeros.
EPA appreciates the comment and will implement as suggested.
-0054
Row 7 Column A - 2. General Tank / Separator Information - Complete for each Tank / Separator:
 If separators are included, Table 2 should only apply to >= 10 bbl/day.
 Black out for T&S. Include a trigger in the row for Separators >= 10 bbl/day to provide information in Table 2.
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day. However, for transmission and storage facilities that do not have separators that have 10 bbl/day liquids, EPA is requesting that parent companies sample one separator.
-0061
The scope of Table 2. General Tank / Separator Information should be limited to atmospheric storage tanks. These suggested changes to Table 2. General Tank / Separator Information limit the scope to collect information on crude oil, condensate or produced water atmospheric storage tanks only, where the bulk of gas emissions occur:
 Pressurized separators should be removed by modifying the heading for the first column to `Atmospheric tank/separator IDs'. Pressurized separators have no atmospheric emissions except for fugitives, so the data has no practical use in this survey.
 `Vessel types' should be limited to fixed roof atmospheric storage vessels or floating roof atmospheric storage vessels.
 Is there continuous monitor for Vessel Operating Pressure' should be eliminated from Table 2 General Tank / Separator Information. Only atmospheric storage vessels should be considered within scope of the ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Multiple tank IDs should be entered into a single row, when a single feed stream is stored in multiple tanks.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
 For the column "Vessel Type," one of the drop down selections is "Heater/treater." However, the defined term is "Heater treater." One of these should be changed to align with the other.
 "Vessel Type" options are confusing. For example, a heater treater is a gas-liquid separator with heat, but "heater treater" and "gas-liquid separator" are both options. EPA should eliminate one of these options.
 EPA lists two options for "ambient storage tank." This term is not defined and is confusing. All storage tanks are ambient tanks, as tanks are not heated, and pressurized tanks are excluded from this portion of the survey. These two categories should be deleted as they have no relevance, and they are redundant of other categories (i.e. Condensate storage tank and fixed roof storage tank).
"Heater/treater" has been corrected to "heater treater".

EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Ambient storage tanks have been corrected to say "atmospheric tanks."

-0061
The regulatory column header should specify that the list of regulations apply to the tank only and New Source Review Permits should be added as a separate option for selection.
The regulations that apply have been adjusted.

-0054
Row 8-58 Column C - List current environmental regulations to which the well site must comply.
Select all that apply.
 This should be consolidated in the facility tab and answered once for the facility.
 Move to Facility tab. Change "well site" within column title to "facility" or appropriate term. Include 40 CFR 98 in the list of regulations.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Sub-Section 2. General Tank/Separator Information  -  Complete for each Tank/Separator
"List current environmental regulations to which the well site must comply"
 EPA should include an "Other" category.
"Other" has been added to the spreadsheet.
-0061, 54
`Vessel height (ft)' and `Vessel Diameter (ft)'should be removed..
Vessel height and vessel diameter have been removed and vessel capacity has been added.

-0054
Row 8 Column F and G - Average vessel hydrocarbon (F) or water (G) throughput (bbl/day)
 For all or most facilities, hydrocarbon throughput is only available for the atmospheric storage tanks not for each separator vessel/filter separator.
 Black out for T&S. If included, establish a hydrocarbon threshold. Throughput volume available for T&S would include hydrocarbons and water (if any).
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
The information on `Continuous Monitoring' is not related to emissions and should be removed in its entirety. Typically, there is no measurement occurring to or from a storage vessel at production facilities.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
"Is there a continuous monitor for the following:"
 Cells K7, L7, and M7 should be merged with cell H7:J7 to clarify that H8 through M8 are all under the section "Is there a continuous gas monitor for the following."
 "Is there a continuous monitor for the following: Gaseous flow rate to the vessel?" It would be extremely unlikely to have a gaseous flow meter to liquid storage tanks.
 "Is there a continuous monitor for the following: Liquid feed flow rate to the vessel?" Continuous monitors like these are very rare, but to the extent they exist, GPA Midstream does not see how this information will be helpful for rulemaking.
 "Is there a continuous monitor for the following: Liquid flow rate from the vessel"  - there should be a note saying that if vessel type is a tank, then this question is not applicable, because liquids removed from the tank during intermittent liquids unloading would not count as continuously monitored.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Add "Total days of operation" to Table 2.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Table 3: Feed Material Characteristics

-0061
`Type of feed material' should be restricted to atmospheric storage tanks accumulating crude oil, condensate, intermediate hydrocarbon liquids, or produced water only.
EPA appreciates the comment but we desire to collect information on separators in this section to better understand flashing measurements in Table 4. We have limited the dropdown options to eliminate storage tanks that are not included in the ICR (amine, glycol or fuel storage tanks).
-0046
Sub-Section 3. Feed Material Characteristics  -  Complete for each Tank/Separator
"Tank/Separator ID"
 Revise to "Tank ID"
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Column A is auto-filled from Table 2; therefore, EPA should delete `/separator ID' in the heading to match the Table 2 heading.
EPA instead revised Table 2 heading to be "Tank/Separator ID" so the column headings match between tables.
-0054
Row 77-86 Column A-B - Separator ID/Tank ID
 Unique IDs may not be available for each tank separator, meaning that respondents would likely make up IDs solely for the purpose of responding to this item.
 Remove question. If applicable to T&S, correct pull down links for IDs.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 61 Column B - Type of feed material
 Condensate and natural gas streams may contain trace amounts of water and "definitions" for pull down menu are not clear. The pull down menu does not include all of the possible options for stream types.
 Black out for T&S. If included, EPA must clarify how to characterize tank/separator streams and select from menu; definitions, guidance, and instructions are needed and additional stream options may be needed.
Other (specify) is included.
-0061
`Reid vapor pressure of feed material (psig)' is not useful for unstabilized hydrocarbon streams and should be removed from Table 3. Feed Material Characteristics.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
EPA should clarify that the desired temperature and pressure should be at the separator. Separator temperature and pressure at the time any pressurized sample is taken is critical for running a process simulation to calculate flash emissions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Sub-Section 3. Feed Material Characteristics  -  Complete for each Tank/Separator
"Pressure of feed material (psig) and Temperature of feed material (°F)"
 EPA should clarify if the "Pressure of Feed Material" and "Temperature of Feed Material" is an average.
EPA appreciates the comment and will implement as suggested.
-0061
Specific gravity of the pressurized sample per `Specific Gravity of feed material (relative to water at 4 C)' has no practical meaning and should be removed from Table 3. Feed Material Characteristics.
EPA appreciates the comment and will implement as suggested.
-0061
The average temperature and pressure are assumed to be of the atmospheric storage tank. This should be clarified and the atmospheric storage tank pressure should be in inches of water column.
EPA appreciates the comment and will implement as suggested.
-0046
Sub-Section 3. Feed Material Characteristics  -  Complete for each Tank/Separator
"Average temperature of liquids in vessel (°F)"
 This can be assumed to be ambient temperature and can be ascertained using meteorological data.
EPA appreciates the comment and will implement as suggested.
-0046
Sub-Section 3. Feed Material Characteristics  -  Complete for each Tank/Separator
"Average operating pressure of vessel (psi)"
 EPA needs to specify either "psia" or "psig". GPA Midstream suggests "psig" to be consistent with other data items.
 If EPA makes the decision to limit this data collection form to tanks only, this should be eliminated as EPA not collecting information from pressurized storage tanks.
EPA appreciates the comment and will implement as suggested.

Table 4: Feed Material Composition

-0046
Sub-Section 4. Feed Material Composition
 The fields "Separator ID from which sample is collected" and "Tank ID(s) for which this material is used as feed" contain dropdown selection options, but these fields should be open text entry.
EPA appreciates the comment and will implement as suggested.
-0046
In midstream gathering operations, not all separators feed directly to storage tanks, so this table could result in correct or misleading information.
EPA appreciates the comment and will implement as suggested.
-0061
EPA should change the table name of Table 4. Feed Material Composition to Table 4. Feed Material Flash Gas Properties to be consistent with the data they are interested in collecting. Unless the operator is familiar with the CARB Method, the current title (Feed Material Composition) will lead to reporting of the composition of the pressurized liquid instead of the flash gas properties.
EPA appreciates the comment and will implement as suggested.
-0061
The current instructions for Table 4. Feed Material Composition does not provide the flexibility needed to determine flash emissions for the variety of domestic oil and gas operations that exist nationwide.
 Recommendation: "Complete the following table with flash gas emission data for each feed material sent to an atmospheric tank using pressurized sample collection from each separator and flash emission analysis (either laboratory measurement or process simulation). The California Environmental Protection Agency Air Resources Board's Test Procedure for Determining Annual Flash Emission Rate of Methane from Crude Oil, Condensate, and Produced Water1 (CARB Method) or other peer reviewed, consensus method is acceptable. If you have performed testing of the feed material composition within the last 5 years, complete the following table based on the test results in-hand. The results of a representative sample may be reported for a feed material if the separator pressures are within 50 psig or 10%, whichever is greater, and the operator has knowledge supporting the similarity of the feed materials. If you have not performed testing of the feed material composition or have a representative feed material analysis, you must sample and analyze the pressurized separator fluid (storage vessel feed material) and report the results of the test in the following table."
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day.
-0061
Samples should only be required from separators that directly feed atmospheric storage vessels and that have a significant pressure drop between the separator and storage vessel.
 The CARB method is only applicable to the first separator that dumps into an atmospheric tank. Table 4 instructions should be amended as revised below to eliminate atmospheric storage tank feed samples that do not have a significant pressure drop from separator pressure.
 Tank feed streams with very low pressure separators should be exempt from sampling requirements. Many operators have installed two stage separation, with the separator feeding the atmospheric storage tank having very low operating pressure (i.e., <15 psig) and the vapors from that separator recovered to sales gas.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Eliminate `Separator ID' from the column heading of Table 4. Feed Material Composition. As discussed above, separator information should not be collected. Thus, the separator ID has no utility.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Add a `Flash Emission Determination Method' column to Table 4. Feed Material Composition. The pick list options should be:
 The CARB Method
 Other Peer reviewed, consensus method
 Pressurized liquid compositions and process simulation
 Combined natural gas and crude oil/condensate production volume and composition data, using process simulation
 Representative sample
 Direct measurement (See Table 6 Direct Emissions Measurements for results)
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Label the compositions in addition to the individual components in Table 4. Feed Material Composition.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
The VOC column should be eliminated from Table 4. Feed Material Composition.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
The GLR column should be labeled `Gas Liquid Ratio of Flashed Pressurized Sample' in Table 4. Feed Material Composition.
EPA appreciates the comment and will implement as suggested.
-0066
EPA should also collect composition information via direct analysis of the feed material in the liquid phase that is stored, processed or passed through tanks and separators for all HAPs, including VOCs and SVOCs.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

CARB Method/Feed Composition Sampling Method

-0061, 49, -54, 48
The Draft CARB Method is an appropriate method of determining flash emissions in heavy oil service, but it is not applicable in all situations and concerns still exist.
 The draft CARB Method is not expected to be finalized until 2017 and has not had adequate peer review to be valid for a broad range of separator pressures and feed compositions.
 It has been applied primarily for produced heavy oil sampled at low pressure separators.
 Determining whether the pressurized sample was representative is not possible from the flash analysis alone.
 Only four laboratories have been located that are familiar with the CARB Method, and only three laboratories in California currently perform the CARB Method. Specifying the use of only this method will limit the amount of data that can be collected in the very short time frame proposed.
 Discussion with laboratory representatives have identified that the CARB Method is not appropriate for areas such as the Uintah Basin and the Denver-Julesburg Basin.
 There may be issues associated with analytical lab support because the CARB method is not broadly practiced.
 This method is undergoing review and comment during an ongoing rulemaking.
 The CARB method is not well-established nationally nor has it been validated.
 Many analytical labs are not familiar with this method.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0061
Obtaining a representative sample for the CARB Method is often difficult, as indicated by using process simulation based on the composition of the pressurized liquid sample as a check.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0054, 49, 61
Analytical lab resources may be strained to complete analysis of thousands of samples during the limited time available with a 120-day schedule. This issue is compounded if analysis is limited to the CARB method. Additional time should be allowed to complete feed material sampling and flash analysis. EPA should extend the response time to at least 180 days to respond to both parts of the ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0027, 50, 58, 49, 59
High cost of performing CARB tests.
 Install ports = $5,000/separator
 Sample cost = $3,700  -  $8,700/sample
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
EPA should reduce the scope of sampling due to the significant cost of gathering these data. The pressurized liquid sampling should be limited to sufficient number of facilities that would provide a representative composition analysis for a particular basin.
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day.
-0061, 54, 48
EPA should allow any peer reviewed, consensus method. Laboratory methods should not be limited to those referenced by the CARB Method.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0050, 49, 46
EPA should allow industry to calculate storage tank flash gas by using Gas Processors Association 2186M methodology, or any other methodology advanced by the GPA, as these methods are standard within the industry.
 EPA should allow respondents to calculate storage tank flash gas analysis using the Gas Processors Association (GPA) 2103M, GPA 2186-M, or GPA 2286-M methodologies.
EPA is limiting flexibility of the extended analysis. The acceptable GPA methods are listed in CARB. See the Comments Response Memo for more information.
-0061
Operators should be allowed to use the results of process simulations for gas composition, GLR and MW.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0061
EPA should allow operators to use an alternate approach in lieu of pressurized samples for hydrocarbon liquids. Some existing systems cannot obtain a representative, pressurized sample with existing equipment (i.e., very high pressures [>600 psig] and/or inadequate ports to access liquid).
Operators should be allowed to use alternative approaches to pressurized samples when completing Table 4. Feed Material Composition for produced water tanks. Produced water tanks have very low emissions of methane due to the low solubility of methane in water. As such, the pressurized liquid sampling and flash gas analytical methods (i.e., draft CARB Method and peer-reviewed consensus methods) are not designed to address pressurized produced water samples.
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day. However, for transmission and storage facilities that do not have separators that have 10 bbl/day liquids output need to complete the separator sampling for one of their separators on site. See the Comments Response Memo for more information.
-0061
Atmospheric storage vessels that have similar feed material compositions and separator pressures as other atmospheric storage vessels should be able to reference similar feed stream results within the same field as being representative.
 EPA should allow a single sample to represent the feed material to multiple tanks, as long as the separator pressures are within 50 psig or 10%, whichever is greater, of each other and operators have knowledge supporting that the feed materials are similar.
 The ability to report results of representative analyses would be invaluable to the operator and the Agency in the instance that a sample shows indications that it is not representative during either laboratory analysis or process simulation quality checks (see below for further information). Reporting representative sample results from another location would be more accurate than reporting sample results that are suspect.
 EPA should clarify that sites are not required to install a temporary separator for the sole purpose of collecting a pressurized liquid sample.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0054
Multiple, similar streams may be present at a T&S facility because there is little variability in the streams at these facilities as all streams are associated with pipeline quality natural gas. Therefore, EPA should allow the use of a single analysis of feed material for the facility.
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day. However, for transmission and storage facilities that do not have separators that have 10 bbl/day liquids output need to complete the separator sampling for any one of their separators on site. See the Comments Response Memo for more information.
-0027
EPA should only require sampling and analysis at the final separator leading into a tank, which should be representative for all separators before it.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0027, 58
ICR should only require sampling from a subset of separators at 25% of the facilities targeted.  (Attachment 2F question 4 regarding Feed Material Composition)
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0050
Remove collection of pressurized samples of liquid streams to perform flash analysis request completely from ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0050
EPA should allow operators to provide a representative sample from a nearby well in the case of inability to sample at a given well (i.e. well is shut in and awaiting workover, maintenance issues, low liquid production volumes, etc.).
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0058
Eliminate the requirement to sample tanks located downstream of initial separators associated with natural gas production.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0058
Eliminate the requirement to sample tanks that are not already equipped to be sampled.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. See the Comments Response Memo for more information.
-0066
The analysis of the flash gas should be expanded to include all VOCs.
The extended analysis is already required.
-0054
EPA should allow the use of available information from previous sampling. For example, a facility may have been required to conduct an analysis for a state or permitting requirement. If a T&S facility has such an analysis, it should be able to use it because gas composition at T&S facilities does not significantly change over time.
EPA agrees that if the CARB method was completed within the last 12 months, then those results may be submitted.
-0049
Based on industry experience, many upstream samples tested with this CARB test will come back with 0 or null results due to inadequate pressure. In order to address this issue, the CARB testing methodology is currently being updated but will not be available by the time respondents begin work on the ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
CARB sampling poses logistical challenges, as shipments are classified as hazardous material and require sample containers to be filled to 90% of capacity when many of these containers are designed to be filled to 80% capacity.
With the new version of the CARB method, 80% capacity is allowed.

Table 5: Leakage, Controls and Inspection

-0046
Sub-Section 5. Leakage, Controls and Inspection  -  Complete for each Tank/Separator
"Disposition of natural gas (or other off-gas)"
 EPA is collecting this information with the intent to determine if/how to control tanks, and yet the information requested about current controls is extremely limited and broad. The options here should be similar to Picklist Number 53 with additional options:
 Unassisted candlestick flare
 Air-assisted candlestick flare
 Steam-assisted candlestick flare
 Enclosed flare/combustor
 Thermal oxidizer/incinerator
 Fuel / firebox
 Recovered to facility inlet/process - Include place to indicate vapor recovery downtime/maintenance percentage
 Captured for sales
 Other control (specific) - Include a place to write in the other control device/process
 EPA does not ask about the primary driver for installation of tank controls. This is a major oversight, when the purpose of this ICR is to collect information to determine if and how certain emission points should be controlled.
EPA has added Control Device ID.
-0046
Sub-Section 5. Leakage, Controls and Inspection  -  Complete for each Tank/Separator
"Thief hatch inspection frequency"
 EPA should explain whether simple visual checks are considered an inspection, or whether the term is referring to a full inspection of gasket conditions, operation, etc.
EPA appreciates the comment and will implement as suggested.
-0061
`Pressure release setting for thief hatch or other pressure relief device, as applicable (psig)' in Table 5.
 Leakage, Controls, and Inspection should be removed from the table. The pressure relief setting of the thief hatch or relief valve is typically higher than the operating pressure provided in Table 3. Feed Material Characteristics for `Average operating pressure of vessel (psig)'. Since the operating pressure is already provided, the pressure release setting is not needed and has no utility in quantifying emissions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Sub-Section 5. Leakage, Controls and Inspection  -  Complete for each Tank/Separator
"Pressure release setting for thief hatch or other pressure relief device, as applicable (psig)"
 A tank may have multiple pressure relief devices including a thief hatch and each device may have different pressure relief set points.  EPA does not request information on the types of pressure relief devices, and EPA does not request information on the disposition of emissions from pressure relief devices. EPA appears to be concerned about emissions from overpressure events (stuck dump valves), however, the EPA also does not ask about inspection of pressure of relief devices after an overpressure event.
EPA has separated to ask thief hatch and PRD separately.
-0046, 54
Sub-Section 5. Leakage, Controls and Inspection  -  Complete for each Tank/Separator
"Hours dump valve stuck in 2015"
 This data is not tracked and is not available for many facilities.
 If EPA decides to require this information, a "Not Available" option should be allowed.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0067
EPA should amend Table 5 2F by adding the
following instructions and questions:
 Choose one of the following options regarding the disposition of natural gas (or other off gas) from storage tanks:
            a. A vapor recovery unit,
            b. An internal thermal combustor,
            c. A flare,
            d. Venting to the atmosphere (i.e., without combustion or recovery),
            e. Other (please describe).
EPA has added Control Device ID.
-0067
Add the following questions to Table 5 2F:
1. What is the pressure of the liquid in the final vessel before it reaches the storage tank?
2. What is the diameter of the piping that conveys material from the separator(s) to the storage tank(s)?
3. What is the diameter of the piping that conveys material from the storage tank(s) to a control device?
4. Is the piping sized sufficiently to prevent back pressure during peak flow emissions? (Back pressure may cause gases to flow out relief valves or the
thief hatch to the atmosphere)
5. What measures have been taken to ensure that dump valves do not stick open leaving natural gas or other off gases to overwhelm the emission control devices?
6. Please select any of the following options regarding maintenance plans for relief valves on storage vessels equipped with emission control equipment.
7. What is the set point for each pressure relief valve?
8. What is the set point for each thief hatch?
9. Please identify the gasket material for each thief hatch? Please describe any criteria considered in selecting the gasket material.
10. Is there a procedure in place that ensures that thief hatches are closed after unloading liquids or gauging occurs? If yes, please provide a description of the procedure.
11. What kinds of alarms exist to let operators know that the thief hatch is open?
12. Please provide the name of the manufacturer and the installed cost of the alarming device.
13. How many times was the alarm triggered in 2015?
14. If the alarm was installed after January 1, 2015, please provide the installation date and number of times the alarm was triggered since installation.
EPA has added some of these questions, some are already being asked, and the rest the EPA has considered and evaluated the impacts of this comments and has decided not to pursue any further action.
-0068
Add the following questions to Table 5:
 Number of times pressure relief valves are tested per year for their proper pressure release settings
 Hours of improper release via PRV or thief hatch (due to failure to reseat, failure to close thief hatch, misaligned gasket, etc.) in 2015
 Number of instances of improper release via PRV or thief hatch (due to failure to reseat, failure to close thief hatch, misaligned gasket, etc.) the 2015 calendar year (count)
 Number of instances of stuck dump valves in the 2015 calendar year (count)
 Type of control measure in place; vapor recovery compressor, eVRU, ejector, enclosed combustor, open flare, other?
 If other, list the type of other control
 If vapor recovery compressor, list the type of compressor; reciprocating, centrifugal, scroll, screw, vane, other?
 Capacity of recovery/ control option (Mscf/day)
 Maximum liquid production per day at the well site in the 2015 calendar year
 Minimum liquid production per day at the well site in the 2015 calendar year
 Operating hours of recovery/ control option (Mscf/day)
 Does the tank use blanket gas?
 If blanket gas is used, what type?

EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

EPA is asking for the number of releases via PRV or thief hatch.

Questions on dump valves similar to thief hatches and PRDs have been added.

Types of control measures in place are in compressor and controls tab.

Table 6: Direct Emission Measurements

-0046
EPA should expand the instructions or add a column (measurement date/year) to address tanks that were measured multiple times over the last 5 years.
EPA appreciates the comment and will implement as suggested.
-0046
Sub-Section 6. Direct Emission Measurements  -  Complete for each Tank/Separator, as applicable, for which emissions measurements data are available
"Source Description"
 EPA should clarify the expected response for this request.
Source description means where emissions are being measured.
-0068
Add the following to Table 6:
 Flashing, working, and standing emissions
 Dump valve emissions
 Flashing, working, and standing emissions measurement equipment
 Dump valve emissions measurement equipment
 Date of measurement (month and year)
Table 6 has been unconnected.  Multiple tests per tank are allowed now.  Date of measurement and speciation has also been added.

Other/General

-0061
Operators should be exempted from completing Table 4. Feed Material Composition if Table 6. Direct Emission Measurement is completed.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

-0061
Operators should be exempted from completing Table 4. Feed Material Composition if pressurized liquid sample and analysis was done within the past 5 years, consistent with the direct measurement allowance.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

-0031
Explicitly list as exempt from the ICR survey tanks that store the following materials: unused triethylene glycol, lube oil, used lube oil, wastewater with negligible hydrocarbon content (e.g. floor cleanup wastewater), odorant, and diesel and gasoline for facility use. Also, exempt tanks with capacity <500 gallons from the ICR.  These tanks have negligible GHG and VOC emissions.
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day. However, for transmission and storage facilities that do not have separators that have 10 bbl/day liquids output need to complete the separator sampling for any one of their separators on site.
-0058
EPA needs to clarify what types of facilities would be expected to respond to Tanks/Separators Sheet worksheet 2F (appears to call for information about tanks and separators at production well sites only). This worksheet should be limited to upstream tanks in production operations. In transmission and storage facilities downstream of gas processing, natural gas is pipeline quality, the potential emissions from tanks with separators are insignificant, and sampling is not warranted. (worksheet 2F ("Tanks Separators") question 4 (rows 73  -  75))
Tanks sheet is applicable to all sites with storage tanks.  EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day. Transmission and storage facilities that do not have separators that have 10 bbl/day liquids output need to complete the separator sampling for any one of their separators on site.
-0066
EPA should collect specific information on the disposition of all liquids (injected and recovered) and/or wastewater and the volume sent to open-air impoundments, percolation pits, and surface discharged.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0064, 46
The facilities extending over large contiguous properties will have more than 10 tanks/separators. The number of tanks/separators will likely exceed 100. Will these sections be unprotected for additional entries?
More rows have been provided.
-0054
Separator and atmospheric tank flashing emissions are trivial in the T&S segment because the natural gas has already been processed. Therefore, the tank reporting form should not be required for T&S. If required, the Part 2 "Tanks Separators" form should be modified for T&S.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
The source of emissions in T&S tanks are from a malfunctioning scrubber dump valve and not working / breathing /flashing losses (consistent with Subpart W). Subpart W data to date confirms this is an insignificant emissions source. In addition, questions may be appropriate for tanks and not separators (or vice versa), but delineation is not provided. Black out for T&S.
If retained for T&S, add clarification regarding applicability of questions for tanks, separators, or both. Or, provide separate fields or separate forms for tanks and separators.
EPA has adjusted the spreadsheets as appropriate.
-0054
Compressor stations may include small separators that are used to protect equipment (e.g., compressor drivers) from small amounts of liquids that may accumulate along a pipeline, and those small separators should be excluded. In this case, detailed information, including flash analysis sampling, would not be required for T&S tanks. If a request for more detailed information (including sampling) is retained, EPA should establish a throughput threshold.
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day. Transmission and storage facilities that do not have separators that have 10 bbl/day liquids output need to complete the separator sampling for any one of their separators on site.
-0054
EPA should only require equipment details, feed material sampling and flash analysis if the separator or tank throughput is greater than or equal to 10 barrels per day.
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day.Transmission and storage facilities that do not have separators that have 10 bbl/day liquids output need to complete the separator sampling for any one of their separators on site
-0046
Request only information regarding those tanks and vessels meeting the current description found on the definitions tab.
EPA has reduced the scope of sampling for separators with liquids output below 10 bbl/day. Transmission and storage facilities that do not have separators that have 10 bbl/day liquids output need to complete the separator sampling for any one of their separators on site
-0046
In midstream, separators are always flow through process vessels where the overhead gas is contained within the process. Midstream operators are focused on moving the customer's gas to market. GPA Midstream member companies would never have a separator designed to route gas to the atmosphere or to a control device. Gathering and boosting facilities typically have a facility inlet separator (or two) (also called the inlet receiver or slug catcher) which receives all the gas the facility will process. Any liquids that accumulate in the vessel are sent to a tank or a stabilizer unit. The gas continues through the process, which almost always includes compression.
EPA appreciates the comment.
-0046
During compression of the gas, some liquids may "drop out" of the gas stream as the pressure is increased. This being the case, compressors have interstage separator (also called knock out pots) that receive the compressed gas/liquid mixture and drop out any liquid after each stage of compression (compressors can have one stage or multiple stages). The small amounts of liquids that accumulate in these vessels are either sent to a tank, stabilizer unit, or back to the inlet receiver.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Some midstream facilities have stabilizer units (also called stabilization units) which receive liquids from the inlet separator and drive off flash gas either through pressure drop and/or heat. The stabilized liquids are then sent to tanks. The gases are either captured for sale or combusted. At these facilities, the stabilizer liquid composition, temperature, and pressure have little bearing over the tank liquid composition, temperature, and pressure. As such, EPA should clarify that liquid samples should be taken at the location that best represents the liquids received by the tank.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
In production, separators that do have emissions (typically the low pressure separators, which are sometimes heated and would therefore also be defined as heater treaters) are controlled differently than tanks, and they need to be evaluated separately in this ICR. The primary difference is that the gas volume emitted from the production low pressure separator is much higher than flashing/working/breathing losses from tanks. Thus, different control technologies would need to be applied. For example, an enclosed vapor combustor might be adequate control for a tank, but multiple enclosed vapor combustors may be required to handle the volumes from a low pressure separator. Likewise, recovery might be a good option for low pressure separators due to large gas volumes, but recovery might not work for tanks because the volumes might be too low to keep a vapor recovery unit running efficiently. Thus, even in the production segment where separators can be emission sources, the profile of their emissions and their controls are very different than tanks; therefore, it does not make sense for EPA to treat separators and tanks in the exact same manner in the survey.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Tank color is not being requested, but this may be a necessary data point to understand tank temperature fluctuations which lead to breathing losses (EPA asks for average operating temperature, which does not assess these fluctuations). Alternatively, EPA should clarify that only flashing losses are being assessed.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0048
The "Tanks Separators" worksheet titles is a confusing term not used in the oil and natural gas industry. EPA should clarify if this is referring to Separation Equipment.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Pneumatics Tab

Table 1: Facility Information

-0046
 Provide a dropdown or check box to communicate that the facility is on supplied/instrument air.
 Instrument air driven devices should be exempted from the ICR altogether rather than a dropdown for the whole facility.
Companies should provide best available data when responding to the ICR.

Table 2: Pneumatic Controllers/Devices/Pumps Inventory
-0054
Row 6-15 Column A - Type of Pneumatic Device
 Provide definitions and ensure definitions are consistent with Subparts W and OOOOa.
 Clarify: service type is mixed with bleed type.
 Carry revised definitions through entire pneumatic tab, tables and pull downs.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 6-15 Column B - Number of Natural-Gas Driven Devices
 There are safety concerns with requiring field counting and data gathering because it is difficult to access some pneumatic actuators to locate the nameplate.
 Allow sufficient time to collect data, which would provide the ability to address potential safety hazards. Or allow use of a surrogate count of the number of pneumatic devices per compressor or tank.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Classification of intermittent vent controllers into throttling or snap-acting should be removed from Table 2. Pneumatic Controllers/Devices/Pumps A.Inventory.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 6-15 Column C - Number of Air-Driven Devices
 The number of air-driven devices is not pertinent to the identification of the types and prevalence of VOC or GHG emission controls or emission reduction measures and potential costs for the measures and controls. Air driven pneumatic actuators are not a source of VOC or GHG emissions.
 Remove question. If field is retained, recommend alternative question: Is there an air system available for pneumatics at the facility? [Y/N]
EPA has added a separate column for air driven devices.

-0061, 31, 64
Remove information collection of air driven pneumatics counts from Table 2. Pneumatic Controllers/Devices/Pumps Inventory.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Remove rotary vane and turbine actuators from Table 2. Pneumatic Controllers/Devices/Pumps Inventory.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Remove information on Kimray pumps from Table 2. Pneumatic Controllers/Devices/Pumps Inventory.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Add 2015 operating hours for liquid circulation pneumatic pumps.
EPA appreciates the comment and has implemented as suggested.
-0068
***SEE CLEAN AIR TASK FORCE COMMENT
Add the following questions to Table 2 FOR EACH PNEUMATIC CONTROLLER/ACTUATOR:
 Device No.
 Vented Controller (Gas-driven pneumatic) (Continuous Bleed or Three-way Valve)
 Vented Actuator (Gas-driven pneumatic) (Snap Acting or Throttling)
 Instrument Air PD
 Electric controllers
 Year of installation
 Supply Line Pressure (psig)
 Equipment Associated with?
 Function (level control, temp control, etc.)
 Measured Emissions Rate (scfh, whole gas)
 Manufacturer Make and Model Number
 If measured emissions rate not available, estimated emissions rate, if available (scfh)
 In the determination of the operator, is this a high bleed, low bleed, intermittent bleed device?
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

-0068
***SEE CLEAN AIR TASK FORCE COMMENT
Add the following questions to Table 2:
 Electricity driven actuators  -  Number of Electricity-Driven Devices
 What type(s) of electricity-drive actuator(s) (e.g., electronic; instrument air; solar powered; VRU; etc.)?
 How is electricity generated (e.g., connected to the grid; solar panels; on-site generation)?
 Chemical/liquid injection/circulation piston pumps - Number routed to process
 Chemical/liquid injection/circulation diaphragm pumps - Number routed to process
 Chemical/liquid injection/circulation piston pumps - Number routed to control
 Chemical/liquid injection/circulation diaphragm pumps - Number routed to control
 Electric pumps  -  Number of Electricity-Driven Devices
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
***SEE CLEAN AIR TASK FORCE COMMENT
Remove the following questions from Table 2:
 Snap acting, intermittent bleed controllers - Number of Air-Driven Devices
 Throttling low continuous bleed controllers - Number of Air-Driven Devices
 Throttling high continuous bleed controllers - Number of Air-Driven Devices
 Throttling intermittent bleed controllers - Number of Air-Driven Devices
 Throttling no-bleed controllers (discharge to downstream gas line) - Number of Air-Driven Devices
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Replace Table 2 references to "Chemical injection" pumps with "Chemical/liquid injection/circulation" pumps. Stating liquid covers all types of pumps
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Kimray pumps are only used for glycol circulation.  Replace Table 2 references to "Liquid" Kimray pumps with "Glycol Assist" Kimray pumps.
EPA appreciates the comment and has implemented as suggested.
-0068
Kimray pumps cannot be air driven.  Remove question "Liquid Glycol Circulation (Kimray) pumps - Number of Air-Driven Devices."
EPA has requested information on "liquid circulation (Kimray) pumps."

Table 3: General Pneumatic Controllers/Devices/Pumps Information
-0061
Revise pick list selections for `How does the facility determine if a device is intermittent or continuous bleed?' to the following:
 Manufacturers' data sheet based calculation,
 Instrumentation design knowledge, or
 Model number and supply pressure.
The picklist options have been added.
-0054
Row 18 Column A-B - How does the facility determine if a device is intermittent or continuous bleed?
 The pull down options are not complete. For example, manufacturer information may be used, but it may not be the minimum or maximum rate (which are menu options).
 Remove question. If field is retained, add options such as "manufacturer specification" to current pull-down menu.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Revise pick list selections for `How does the facility determine if a continuous bleed device is high or low?' in Table 3. General Pneumatic Controllers/Devices/Pumps. The Pick list options should be changed to:
 Manufacturer information based calculation,
 Model number and supply pressure,
 Measured gas supply rate
 Measured gas vent rate, or
 Other design considerations.
Picklist options have been updated.
-0054
Row 19 Column B - How does the facility determine if a continuous bleed device is high or low bleed?
 If available, response would be based on manufacturer information. Since pneumatic device emissions are relatively low for T&S segments, respondent should be allowed to use a default option of "high bleed."
 This is a not a significant source for T&S. Allow selection of higher bleed if bleed rate cannot be easily discerned.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 20 Column B - What work practices does the facility employ to identify malfunctioning controllers (e.g., intermittent devices continuously venting)?
 Incomplete pull down, include "audio" with visual in pull down menu. Include routine audio/visual inspections of controllers.
Audio/visual has been added to the picklist.
-0046
Sub-Section 3. General Pneumatic Controllers/Devices/Pumps Information
 The question, "What work practices does the facility employ to identify malfunctioning controllers (e.g., intermittent devices continuously venting)?" should allow for multiple selections (versus a single drop-down selection).
Picklist options and other has been added.
-0054
Row 21 Column A - How many controllers were found malfunctioning in the past year?
 A device may have been malfunctioning for reasons that do not contribute to VOC or GHG emissions. Records may not be available for the number of malfunctioning components and the number of malfunctioning controllers is not determinable for the past year.
 Remove question.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 22 Column A - What is the natural gas supply pressure for the pneumatic devices (psig)?
 The supply pressure can be device specific (with a regulator). Facility pressure is available, through Subpart W, but it is not pertinent to device function.
 Remove question
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Add parameter `List current environmental regulations to which the pneumatic controllers must comply. Select all that apply.' to Table 3. General Pneumatic Controllers/Devices/Pumps. The picklist options should be limited to:
 None,
 State Regulation or Permit
 NSPS OOOO/OOOOa, and
 Both State Regulation/Permit and NSPS OOOO/OOOOa.
EPA appreciates the comment and has implemented as suggested.
-0061
Add `Does facility use practices to minimize natural gas emissions from pneumatic devices or pumps?' to Table 3. General Pneumatic Controllers/Devices/Pumps. Pick list options should be limited to the following:
 Pumps connected to closed vent system (CVS),
 Pumps routed to control device,
 Air supplied to controllers,
 Solar/electric valves, or
 Other, specify.
EPA appreciates the comment and has implemented as suggested.
-0061
Remove `What is the natural gas supply pressure for the pneumatic devices (psig)?' from Table 3. General Pneumatic Controllers/Devices/Pumps.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Table 4: Isolation Valve Actuations in 2015

-0061
Revise heading from `Isolation valve actuation' to `Pneumatic driven, motorized actuators' in Table 4. Isolation Valve Actuations in 2015.
Table 4 has been adjusted to, "Pneumatically driven isolation valve actuations."
-0054
Row 28-36 Column B - Isolation Valve Actuator Type
 The pull down options are inconsistent with options in row 11 and 12. Add "other" row to rows 11 and 12 to be consistent with the pull down options.
EPA appreciates the comment and has implemented as suggested.
-0054
Row 27 Column C - Actuator Size (include description, if "other" selected for type)
 It is not clear what information EPA expects to receive in response to this question or its value. Actuators may have missing or illegible nameplates making it very difficult to accurately identify the size of the actuator.
 Remove question. Any related question retained requires clarification and a description of the value EPA hopes to gain from this data, and EPA estimates of additional costs to gather this data.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
What does the EPA means by "actuator size" and how to appropriately count the cumulative number of actuations? What is this based upon? Engineering estimates?
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 27 Column D - Cummulative [sic] Number of Actuation Cycles in 2015 (or most recent operating year).
 The information on actuations is not available and is indeterminate. Gathering surrogate information on Operations (unit Blowdowns) would not be accurate and would be very labor intensive.
 Remove question. If this field is retained, correct typo "cumulative." If this item is retained, EPA should allow the use of engineering estimates.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061, 31
Records are not typically kept on isolation valve actuation and will typically be an operator's best estimate. The parameter in Table 4. Isolation Valve Actuations in 2015 should be amended to explicitly state estimation is appropriate for clarity on required level of accuracy: `Estimated Number of Actuation Cycles in 2015'.
Companies should provide best available data when responding to the ICR.
-0054
Row 27 Column E - Estimated Device Consumption Rate (scf/actuation)
 These records are not readily available and will likely require contacting the device manufacturer. If the device is missing the name plate or if it is not legible, it may not be possible to accurately obtain the consumption rate.
 Remove question. If retained, EPA should allow the use of engineering estimates or default to a conservative consumption rate of > 6 scf/hr.
Companies should provide best available data when responding to the ICR.

Table 5: Direct Measurements

-0046
"Source Description"
 The instructions are contradictory with the table options. They ask the respondent to complete an entry for each controller/device/pump that was measured in the last 5 years, yet columns D and E are in regards to multiple devices.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 41-49 Column B - Pneumatic Device Type
 The pull down options are inconsistent with options in row 28. Add "other" to the pull down options to be consistent with row 28.
EPA appreciates the comment and has implemented as suggested.
-0068
Add the following questions to Table 5:
 Measurement Method (high-flow sampler, bagging, temporary flow meter installation, other)
 Duration of measurement
 Number of actuations during measurement
EPA has added measurement method, however for duration of measurement and number of actuations during measurement EPA has considered and evaluated the impacts of this comments and has decided not to pursue any further action.

Other/General

-0061, 48
The information collected on Intermittent Vent Controllers could not reliably be used to determine vented emissions due to the variability of the exhaust rate caused by the unique site operations.
 Emissions are highly dependent on operational conditions.
 It would be inappropriate for EPA to use the Part 2 request to draw industry-wide conclusions about hundreds of thousands of pneumatic controllers.
 Intermittent devices are purpose-built for individual facilities, and it is inappropriate to assume that actuation rates on one facility's controllers are representative of industry operations.
 Variability is further compounded by the fact that pneumatic controllers will often actuate at different rates seasonally.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0031, 46
If the intent of the proposed data is to determine if instrument air is available, ask a `yes/no' question, e.g. whether any air-driven devices are in use at the facility. EPA should clarify how sources should respond if company records are not available. If the answer is yes and a number of devices are provided for gas-driven pneumatics, then the question would be answered without an unnecessary count of air-driven devices.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
EPA should simplify the request for instrument air pneumatic, electronic, and mechanical controllers. If facilities are able to use instrument air, they will generally do so for all controllers. Therefore it is unnecessary to gather additional information on actuation rates, snap acting versus throttling controllers, etc. for these devices.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0031
Provide limits for companies, such that they are only required to perform a count of equipment components and pneumatic devices for half of their surveyed facilities or a maximum of 5 facilities
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0031
For facilities that are designed with identical equipment, allow the use of one physical count for each similar facility rather than requiring separate physical counts.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0050
Clarify if EPA is only seeking information relating to pneumatic controllers and does not need information related to pneumatic valves or actuators that do not have the potential to emit.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0050
Limit requested data to pneumatic controllers (not pneumatic pumps) as this is the only aspect of a pneumatic device that actually emits natural gas.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0058, 54
EPA should clarify that the pneumatic device worksheet does not need to be completed for transmission pipelines.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
The ICR introduces new terms and device categories ("snap acting" intermittent controllers and "throttling" low continuous bleed, throttling intermittent bleed, and throttling high continuous bleed controller categories) that are not consistent with Subpart W. As a result, respondents cannot use existing Subpart W device counts and they will need to expend additional effort to understand the Proposed ICR categories, and develop plans to collect data according to those categories. Black out for T&S.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049, 48
The survey should collect pneumatic controller data on high-bleed, low-bleed, and intermittent-bleed devices only. The request for rotary vane isolation valve actuators, snap-acting vs. throttling intermittent-bleed controllers, and turbine operated isolation valve operators would not meaningfully improve the quality of data collected and is not commensurate with the substantial burden on respondents.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
The Intro worksheet instructions for pneumatics states, "You must complete the pneumatic device counts in Section 2 of this form based on actual counts at the facility if natural gas-driven pneumatic devices are used." EPA Supporting Statement at 33. This statement would imply (correctly) that pneumatic devices operating on supplied air systems are not required to be counted. However, on the pneumatics tab in section 2, a count is required for all air-driven devices. EPA Supporting Statement at 52.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
EPA should add a section to the Part II pneumatics section to allow operators the ability to designate whether a pump, valve or controller is controlled by a control device. To be consistent with industry best practices, operators often vent these pneumatics to a control device or re-capture the gas.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
General support for section 3 information collection on work practices and malfunctions, as it will provide EPA with useful context for evaluating work practice standards to ensure the controllers are operating as designed.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

AGRU Tab

Table 2: General AGRU Information

-0061
The `AGRU Type' selections in Table 2 should be modified to include commonly used amine absorbers.
EPA appreciates the comment and has implemented as suggested.
-0061
The regulations listed should be limited to those applicable to AGRUs in Table 2.
EPA appreciates the comment and has implemented as suggested.
-0061
`Relative selectivity of H2S over CH4 (Mass ratio)' and `Relative selectivity of CO2 over CH4 (Mass ratio)' should be removed from Table 2. General AGRU Information. The "relative selectivity ratio" is not a valid predictor of methane in the off-gas stream, since the amine is not saturated with all three gases.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
EPA should only require operators to provide either `Average volumetric flow rate of feed natural gas (scfm)' or `Average volumetric flow rate of treated natural gas (scfm),' in Table 2. General AGRU Information, but not both. Volumetric flowrate is typically available only for either feed or treated gas, not both. `Type Natural Gas Volume Provided' should also be added to specify correct application of the volumetric flowrate per the above recommended change; with pick list options of `feed gas' or `treated gas'.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
The disposition of off-gas must be treated the same for H2S and CO2. These columns in Table 2 should be combined.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
`Contactor Tower Pressure (psig)' and `Circulation Rate of Solution (gallon/minute)' should be added to Table 2. General AGRU Information. The contactor tower pressure and temperature, the type of amine used, and the circulation rate define the rate (pounds/hr) that methane is absorbed into the amine.
EPA appreciates the comment and has implemented as suggested.
-0061
Add operating hours in 2015 to Table 2.
EPA appreciates the comment and has implemented as suggested.

Other/General

-0061
EPA should request the methane mass rate in the off-gas from the most recent process simulation. Natural gas flowrate and compositions of methane, CO2 and H2S are not pertinent to the calculation of methane emissions. Type of amine, amine circulation rate, contact tower pressure and temperature are the primary factors determining methane in AGRU off-gas.
Facilities can take process simulations, but we still believe this information is pertinent.
-0046
Are there limitations on what is considered a direct emissions measurement? Some AGRUs have a volumetric flow meter on the acid gas vent and/or may also have an online gas chromatograph on the acid gas. EPA should clarify as to whether EPA would consider data from these to be a "Direct Emissions Measurement."
Yes, and the emissions would be whole gas flow rate.
-0046
EPA should allow respondents the option to upload an AMINECalc model in lieu of providing information on the AGRU tab. This will provide EPA the composition, equipment configuration, and emissions information it needs in a readily-usable format.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Dehyd Tab

Table 1: Facility Information

Table 2: General Dehydrator Information

-0046
Sub-Section 2. General Dehydrator Information  -  Complete for each Dehydrator
"Dehydrator Type"
 Add "ethylene glycol" in the dropdown list for "Dehydrator Type".
EPA appreciates the comment and has implemented as suggested.
-0054
Row 8-43 Column D - List current environmental regulations to which the well site must comply.
Select all that apply.
 Move to Facility tab. Change "well site" to applicable term. Include 40 CFR 98 in list.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061, 46
Volumetric flowrate is typically available only for either feed or treated gas, not both. Only one parameter should be required in the survey.
EPA appreciates the comment and has implemented as suggested.
-0054
Row 8-43 Column E-L - Feed Gas and Treated Gas column headers
 For information on feed and treated gas, EPA should allow the use of GLYCalc runs instead.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
 "H2O concentration in feed gas (% by vol)"
 GPA Midstream recommends that this match GlyC GlyCalc, which includes two options: "Gas is saturated" or "Gas is subsaturated." If the latter option is selected, the use can input the water content in units of `lb H2O/MMSCF' rather than `% by vol' as requested in the ICR spreadsheet.
EPA has revised the units of H2O concentration in feed gas.
-0061
Composition in and out of the unit should not be collected. Trying to calculate mass rates of methane and CO2 by measurement and mass balance is impractical due to low solubility and measurement error.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
EPA should request `Contactor tower pressure', `Glycol circulation rate', `Circulation pump type', `Runtime hours', and `Stripper gas consumption rate', and `Stripper gas methane composition'. Contactor tower pressure and glycol circulation rate are primary factors in calculating methane emissions from dehydrators.
EPA appreciates the comment and has implemented as suggested.
-0068
Add the following questions to Table 2:
 Temperature of feed gas stream (°F)
 Pressure of feed gas stream (psig)
 Is the gas saturated or subsaturated?
 Hours of operation in the 2015 calendar year
EPA appreciates the comment and has implemented as suggested.

Table 3: Glycol Dehydrator Information

-0054, 46
Row 47 Column C - If yes, provide methane recovery efficiency (percent)
 For information on natural gas recovery efficiency, EPA should allow the use of GLYCalc runs instead.
 Change "methane" to "natural gas"
EPA appreciates the comment and has implemented as suggested.
-0046
Sub-Section 3. Glycol Dehydrator Information - Complete for each Glycol Dehydrator
"Disposition of reboiler/regenerator exhaust"
 EPA is inappropriately combining two emission points (reboiler exhaust and the regenerator still vent); these should be separated.
 For the regenerator still vent, EPA needs to account for multiple controls (condenser to combustion), which is a very common configuration. EPA should also take the opportunity to request more granular information about how the regenerator still vent gas is controlled (i.e., type of flare, thermal oxidizer, vapor combustor, etc), versus the generic "flare or thermal oxidizer).
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Average fuel gas rate should not be requested. Methane emissions from regenerator still reboilers are insignificant because methane is combusted to CO2 and these reboilers have low heat requirements.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054, 46
Row 47 Column H - Glycol reboiler/regenerator fuel gas consumption rate (scfm)
 The most readily available units for the fuel gas consumption rate are in MMBtu/hr. Operators should be able to select preferred engineering units.  If only one option is allowed, use MMBtu/hr rather than scfm.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
The `Source of fuel' is not tied to emissions and should be removed. If the `Source of fuel' parameter is not removed, `indirect heat' should be added as an option to cover gas processing plants that utilize steam in the regenerator still reboiler.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 48 Column K - Emission reduction work practices used
 Sometimes multiple work practices are used on a single glycol dehydrator. Allow for "multiple" work practices in pull down options.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Sub-Section 3. Glycol Dehydrator Information - Complete for each Glycol Dehydrator
"Emission reduction work practices used"
 `Reboiler condenser gas' is very unclear and could be mistaken for multiple streams within a dehydrator unit.
 These columns should be removed from the spreadsheet due to the ambiguity and based on the fact that other columns address the configuration of the dehydrator including emission control devices.
 EPA is not requesting sufficiently granular information about NESHAP HH/HHH that would truly inform EPA about the emission sources and their current control requirements.  EPA should add the following:
 Is the dehydrator at an area source or major source?
 Is the dehydrator a large glycol dehy, existing small glycol dehy, or new small glycol dehydrator?
 For area source TEG dehydrators, does the dehydrator meet with <3 mmscfd throughput exemption, the < 1 ton per year (tpy) actual emissions exemption, neither or both?
 For non-exempt area source TEG dehydrators, is the dehydrator located within a UA plus offset and UC boundary14?
 For major sources, large dehydrators, are dehydrators complying with the 95% HAP reduction requirement or the 1 tpy benzene emission requirement?
 For major source small dehydrators, what is the BTEX emission limit?
 EPA does not request the glycol circulation rate, which is an operating data point that directly relates to emissions.
 EPA does not ask if the glycol pump is electric or natural-gas driven pneumatic, which also impacts dehydrator emissions (pneumatic pump emissions are part of dehydrator process and emitted from the regenerator still vent)
 If EPA pursues information about desiccant dehydrators, EPA needs to ask about vessel opening frequency (once/year, once/two years, once/three years) and emissions during opening.
EPA has revised the Glycol dehydrator information tab to include information on:
 Area Source/Major Source status of facilities
 "actual annual average nat gas flow rate
 date of construction/reconstruction"
 Exemption criteria
 Circulation rate of solution" which is the same as glycol circulation rate.

-0068
***SEE CLEAN AIR TASK FORCE COMMENT
Add the following questions to Table 3:
 If yes, flash tank pressure
 If yes, flash tank temperature
 If yes, is flash gas captured?
 Number of absorber stages
 Lean glycol water content
 Lean glycol recirculation ratio
 Is stripper gas used in the regenerator?
 If yes, the flow rate of stripper gas (scf/min)
 If yes, the methane volume percent in stripper gas (0% if nitrogen)
 Is there a condenser on the regenerator/reboiler?
 If reboiler/regenerator/condenser exhaust is controlled, type of control (vapor recovery to sales, vapor recovery for use on site, to flare)
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Remove "Disposition of reboiler/regenerator exhaust" from Table 3.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Table 4: Direct Emissions Measurements

-0054
Row 57-63 Column C-F - 4. Direct Emissions Measurements - Complete for each dehydrator for which emissions measurement data are available.
 Allow the use of GLYCalc runs. Direct stack measurements are rarely completed since software tool is available and cited in related regulations.
EPA appreciates the comment and has implemented as suggested.
-0068
Add "Measurement equipment used (temporary meter, hi flow sampler, calibrated bag)" to Table 4.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Other/General

-0046, 61
EPA should allow respondents the option to upload a GLYCalc, Version 3.0 or higher file in lieu of providing information on the Dehydrator Units Tab.  Many responders already must prepare a GLYCalc run to comply with NESHAP requirements under Subpart HH, permit requirements, and/or emission inventory reporting. In addition, the GLYCalc runs will provide EPA the composition, equipment configuration, and emissions information it needs in a readily-usable format.
GRI-GLYCalc or other modeling software runs can be used, but must be inserted into database.
-0061
Separate control devices are typically required for dehydration units. EPA has not included the cost to control dehydration units.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046, 61
EPA should remove desiccant dehydrators from the ICR as they are an extremely small source of emissions (as GHGRP data shows). Or, at the very least, EPA should limit the ICR to desiccant dehydrators that directly emit their regeneration gas to atmosphere. EPA should also ask, for each glycol dehydrator, if the unit is treating process gas or desiccant dehydrator regeneration gas.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0066
Characterization of emissions from glycol dehydrators should include an expansion of the composition analysis of feed and treated gas to include data on individual HAPs and other VOCs, as opposed to just relying on estimation of total VOCs.
EPA appreciates the comment and has implemented as suggested.
-0046
Glycol dehydrators that route all emissions back to the process should also be excluded from this ICR as they are not an emissions source.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Eq Leaks Tab

Table 1: Facility Information

-0046
EPA should change "well site" to "facility" in rows 3-7.
EPA appreciates the comment and has implemented as suggested.
-0054
Row 3-7 Column B  -  List current environmental regulations to which the well site must comply.
Select all that apply.
 Move to Facility tab. Change "well site" to applicable term. Include 40 CFR 98 in pick list.
EPA has corrected "well site" references and added 40 CFR 98 to the regulatory picklist.  Regulations remain in the EqLeak Tab.
-0054
Row 8 Column A - Does the facility conduct routine inspections to identify leaking equipment components?
 The question as stated will not lead to a clear and concise answer. To clarify, suggest differentiating frequent "walk through" from regulatory driven surveys and eliminate "routine" as this is subject to interpretation.
 Insert question: Does the facility conduct regular audio-visual-olfactory (AVO) inspections for leaks? [Y/N]
 Restate original question: Does the facility conduct "other" inspections using instrumentation/regulatory methods to identify leaking equipment? If YES, complete Table 2.
EPA has clarified that "routine inspections" are "regulatory driven inspections."  EPA has also added the question "Does the facility conduct regular audio-visual-olfactory (AVO) inspections for leaks? [Y/N]."
-0046
EPA should divide the question "Does the facility conduct routine inspections to identify leaking equipment components" into at least two parts (or otherwise redraft the section) because, as drafted, this section allows only one frequency and monitoring method. In reality, a company may perform camera inspections, M21 inspections, and AVO inspections each on different frequencies.
EPA has amended the Section 1 to allow for multiple monitoring methods.
-0054
Row 11 Column B - Monitoring method used.
 In the pull down, one of the options is Method 21/OVA. The acronym OVA (organic vapor analyzer) is not defined and could easily be confused with the acronym AVO. Define OVA (organic vapor analyzer) in acronyms to differentiate from AVO (audiovisual- olfactory) or spell out.
 There are occasions when multiple methods are used. Add "multiple" to pull down.
EPA has added a definition of "OVA" and "AVO" to the Acronym List.

EPA has amended the Section 1 to allow for multiple monitoring methods.
-0046
EPA should add Audible, Visual, Olfactory ("AVO") to the monitoring method options list.
EPA has added the question "Does the facility conduct regular audio-visual-olfactory (AVO) inspections for leaks? [Y/N]."
-0058
Pick list 38 (monitoring method) should allow an operator to pick more than one method, as sometimes more than one method can be used to detect and/or measure methane emissions.
EPA has amended the Section 1 to allow for multiple monitoring methods.
-0058
Hi-Flow equipment should be added to pick list 38 (monitoring method), as this is sometimes used to measure flow rate of a detected leak. EPA should also retain the option to pick "other" and allow the operator to specify another method.
EPA has added "Hi-Flow Sampler" and "Other (Specify)" to the monitoring method picklist.
-0049
Under the monitoring method selections, one choice is "Method 21/OVA". This seems to imply these methodologies are equivalent, which is simply not the case. Suggest separating these into two different selections. At some locations operators may perform OVA inspections and not perform Method 21 inspections.
EPA has edited "Method 21/OVA" to "Method 21."
-0054
Row 12 Column A - If Other method, specify.
 Add "If other/multiple method(s), specify."
EPA has added "Other (Specify)" to the monitoring method picklist.
-0068
***SEE CLEAN AIR TASK FORCE COMMENTS
Add the following questions to Table 1:
 Was the inspection performed comprehensive for all components across the facility?
 If not, what percentage of components were surveyed?
 What is the frequency of inspections per year?
 What is the monitoring method used for the leak survey?
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
***SEE CLEAN AIR TASK FORCE COMMENTS
Remove the following questions from Table 1:
 If yes, provide the following information by component type: Gas or Light Liquid Valves - Frequency of inspections.
 If yes, provide the following information by component type: Gas or Light Liquid Connectors - Frequency of inspections.
 If yes, provide the following information by component type: Gas or Light Liquid Pressure-relief Valves - Frequency of inspections.
 If yes, provide the following information by component type: Pumps - Frequency of inspections.
 If yes, provide the following information by component type: Other components in gas or light liquid service - Frequency of inspections.
 If yes, provide the following information by component type: Heavy liquid components - Frequency of inspections.
 If yes, provide the following information by component type: Gas or Light Liquid Valves - Monitoring method used.
 If yes, provide the following information by component type: Gas or Light Liquid Connectors - Monitoring method used.
 If yes, provide the following information by component type: Gas or Light Liquid Pressure-relief Valves - Monitoring method used.
 If yes, provide the following information by component type: Pumps - Monitoring method used.
 If yes, provide the following information by component type: Other components in gas or light liquid service - Monitoring method used.
 If yes, provide the following information by component type: Heavy liquid components - Monitoring method used.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Table 2: Equipment Leak Inventory Information

-0046
Eliminate distinction of component counts by "Gas Service," "LNG Service," "Light Crude Service" and "Heavy Crude Service." This type of distinction is not made in OOOOa for new well sites and compressor stations as it isn't appropriate for the natural gas industry. GPA Midstream questions the practical utility of EPA collecting information for components at gas plants that are already subject to NSPS.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
To get insight on the appropriate frequency of monitoring, EPA should ask about the total number of components found leaking during the first monitoring survey (if within the last 3 years).
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 16-45 Column A - Service / Component Type
 These do not match with Subpart W component types. There are differences in the component types listed depending on the service.
 Consistent definitions and nomenclature with Subpart W and NSPS Subpart OOOOa. If retained, there is a significant burden to gather information using new categories.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 16-45 Column B - Total Number of Components contacting a process fluid that contains 5 percent by weight of any of the following pollutants: VOC, CH4, CO2
 Subpart W and NSPS Subpart OOOOa at compressor stations do not require this information. This is not applicable for T&S.
 Remove question for T&S. If retained for T&S, 120 days is not enough time to complete this task given the number of facilities that will require a site survey.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

-0046
Change the language in cells B15 and C15 to read "Total Number of Components contacting a process fluid or gas that contains at least 5 percent by weight of any of the following pollutants: VOC, CH4, CO2" and "For natural gas processing plants only: Total Number of Components contacting a process fluid or gas that is at least 10 percent VOC by weight," respectively.
EPA appreciates the comment and will implement as suggested.
-0054
Row 16-45 Column D - Total Number of Components Monitored for Leaks During Most Recent Monitoring
Survey
 Subpart W and NSPS Subpart OOOOa at compressor stations do not require this information. This is not applicable for T&S.
 The term "most recent monitoring survey" could be confusing and the responses left to judgment and individual interpretation. More specific answers can be obtained by clarifying the question, see suggested rewording to include "using instrumentation/regulatory methods to identify...."
 Remove question. If retained for T&S, 120 days is not enough time to complete this task given the number of facilities that will require a site survey. If retained for T&S, the recommended header revision: Total Number of Components Monitored for Leaks during most recent inspections using instrumentation/regulatory methods to identify leaking equipment.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

-0054
Row 16-45 Column F - Definition of Leak used for Monitoring Components
 There may be other leak definitions. In addition, GHGRP exempts tubing < (1/2) inch in diameter. Consistency with existing regulations is warranted.
 Add "other" to pull down options. Add a column to specify. Include exemption for small diameter tubing consistent with Subpart W.
EPA has added "Other (Specify)" to the Definition of Leak Used for Monitoring Components list.
-0031
Provide an exemption for equipment component counts for tubing lines <1/2" diameter
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
EPA should either make the leak definition a multiple choice list, or EPA should change cell F15 to "Lowest definition of leak using for Monitoring Components".
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0058
The pick list options for "leak definition" (pick list number 39) are currently limited to parts per million volume (ppmv) levels from 500 ppmv up to 10,000 ppmv, plus "any visible emissions using OGI." An option should be added allowing a facility operator to pick 12,500 ppmv if they used a methane detector set to alarm (for safety purposes) at 25% of the lower explosive limit (LEL), which is equivalent to 12,500 ppmv. In case an operator has data based on Hi-Flow measurements, AGA suggests adding a pick list option for cubic feet per second or minute (i.e. a flow rate measured with a Hi-Flow device).
EPA has added "Other (Specify)" to the Definition of Leak Used for Monitoring Components list.
-0068
***SEE CLEAN AIR TASK FORCE COMMENTS
Add the following to Table 2 FOR EACH NATURAL GAS STREAM:
Respondents need to fill the tables below only for streams that contain 5 percent or greater by weight of any of the following pollutants individually or cumulatively: VOC, CH4, CO2.
 Methane (vol%)
 CO2 (vol%)
 HAPs (vol%)
 VOCs (vol%)
 Inerts (vol%)
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
***SEE CLEAN AIR TASK FORCE COMMENTS
Clean Air Task Force proposed new Tables for component counts (see Attachment 2J in CATF Comments).  Proposed breaking out component counts by sector (Production, Processing, etc.) and collecting the following counts for typical equipment types (compressor, tank, meter, dehy, regulator, etc.):
 Valve
 Isolation Valve
 Blowdown Valve
 Dump Valve
 Flanged Connector
 Screwed Connector
 Pressure Relief Valve
 Open Ended line
 Non compressor seal
 Surface crack/hole
 Other
The component count table format should be repeated to collect information on number of components monitored during the last survey and again for the number of components found leaking during the last survey.

Remove/Replace all questions in Table 2.
EPA appreciates the comment we have added equipment component counts by major equipment types, except that we did not distinguish between different types of valves.

Table 4: Direct Emissions Measurements

-0046
EPA should install a cap on how far back operators need to collect direct emissions data. The title of Table 4 needs to be clarified with the time period.
EPA has amended the Table 4 to request most recent direct emissions measurement data per source.
-0054
Row 61 Column A - 4. Direct Emissions Measurements - Complete for each component or equipment type, as applicable, for which emissions measurement data are available.
 Row 59 inquires about emissions testing, and should be linked to item 4. However, row 59 is only applicable to onshore petroleum and natural gas production facilities. The form should also inquire about data availability for other segments and the question should be linked to the table in item 4.
 Clarify applicability to all segments or only production facilities, include the appropriate question(s) and link a "yes" answer to the Direct Emissions Measurements table. If "no," the table should be blacked out
EPA has requested leak emissions testing data for all sectors.
-0061
Direct emissions measurements should only include methods that quantify emissions. For Method 21 operations, a direct measurement is not obtained as there is no flow rate information.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
"Measurement Method"
 EPA clarify what is meant by these "Screening/..." selection options with respect to equipment leaks. Does EPA intend for operators to report "Screening/..." with a "Measured Emissions Rate" of 0 scf/hr for any components that were screened and did not have emissions?
EPA has amended Table 4 to remove all "Screening/..." options from the Measurement Method picklist.
-0046
"Measurement Cost"
 Direct quantitative measurements are unusual for leaking components, and EPA should not anticipate receiving a substantial amount of data here. These measurements are likely only conducted for special studies.
 EPA should allow (but not require) respondents to submit leak detection program cost information. EPA should add a Sub-Section 5 for leak detection program information, which should request "Annual leak detection program cost", "Inspection type (dropdown option of In House or Third Party), "Equipment Ownership" (dropdown options of In House, Third Party or Rented). EPA should specify in the workbook or in a supplemental instruction that "Annual leak detection program cost" should include all equipment, transportation, recordkeeping software, inspection, component inventory maintenance, and repair costs.
EPA will include the ability to upload additional data (process simulations, supplemental data, etc.) in e-GGRT.
-0068
***SEE CLEAN AIR TASK FORCE COMMENTS
Add the following questions to Table 4:
 Month and Year of last survey performed
 Frequency of surveys per year in the last three years
 Survey equipment used
 Emissions from Valves (scf CH4/hr)
 Emissions from Isolation Valves (scf CH4/hr)
 Emissions from Blowdown valves (scf CH4/hr)
 Emissions from Dump Valves (scf CH4/hr)
 Emissions from Flanged Connectors (scf CH4/hr)
 Emissions from Screwed Connectors (scf CH4/hr)
 Emissions from Pressure Relief Valves (scf CH4/hr)
 Emissions from Open Ended Lines (scf CH4/hr)
 Emissions from Non compressor seals (scf CH4/hr)
 Emissions from Surface crack/hole (scf CH4/hr)
 Emissions from Other components (scf CH4/hr)
 Was the measurement performed by the operator or a contractor?
 If contractor, total leak survey and Measurement cost ($)
 Total time needed for survey and measurement (hours)
 Approximate average time between survey and repair of leak (days)
 Approximate average cost to repair leaks ($)
 Number of leaks repaired
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
***SEE CLEAN AIR TASK FORCE COMMENTS
Remove the following questions from Table 4:
This information is already captured in the revised tables provided by Clean Air Task Force.
 Service type
 Equipment type
 Component type
 Measured Emissions Rate (scf/hr)
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Other/General

-0061, 59
The addition of providing prior leak data should be a voluntary option if data is available. Providing data for only the most recent survey will not allow the agency to evaluate the declining rate of leaks over time.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
The proposed response time does not adequately allow for collection of data included in the draft ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0027
Should use the same Service/Component Type categories as Subpart W.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0058, 54
EPA should clarify that the equipment leak worksheet does not need to be completed for transmission pipelines.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0066
Expand compositional analysis of produced gas to include data on individual VOC and SVOC fractions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0064
There is no guidance on how to complete the component counts or leak data. Does the count stop at the well location or continue through the central processing facilities? For a facility consisting of hundreds of wells, the component counts will take a substantial number of hours to complete.
Component counts should be completed for the facility based on the "facility" definition provided in the Definitions Tab.
-0049
Asking for LDAR to be done on existing sources simultaneously is extremely burdensome and counterproductive to coming into compliance with OOOOa. Strongly recommend that EPA delay this portion of the ICR until after June 3rd.
 EPA has considered and evaluated the impacts of this comments and has decided not to pursue any further action.

Comp Tab

Table 1: Facility Information

-0046
EPA should add more rows in order to allow operators to appropriately respond.
EPA has added several rows to allow responders to account for all compressors.

Table 2: General Compressor Information

-0061
EPA should remove `Engine Type', `Fuel Type', and `Emission Tier' since these parameters relate to engine combustion emissions, not compressor emissions. These three data elements alone are insufficient to determine engine methane emissions with any accuracy (i.e., within an order of magnitude).
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 9-48 Column D - List current environmental regulations to which the well site must comply.
Select all that apply.
 Move to Facility tab. Change "well site" to applicable term. Include 40 CFR 98 in the pick list.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 7 Column F - Engine Type
 This column describes the "Driver" not the engine. Change from "Engine Type" to "Driver Type"
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 9-48 Column F - Engine Type
 A turbine is a commonly used Driver Type. Include Turbine as an option in the pull down list.
EPA has added "Turbine" to the Engine Type list.
-0046
Sub-Section 2. General Compressor Information  -  Complete for each Compressor
"Engine Type"
 "Electric" is not an engine type.  Electric is a type of driver, or motor, for a compressor. EPA should change the column heading to "driver type."
 EPA should add "turbine" to the driver type drop-down menu.
 EPA should exclude Columns E (Power output compressor driver (hp)), F (Engine Type) and G (Fuel Type) as each column pertains to drivers and not compressors.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

EPA has added "Turbine" to the Engine Type list.
-0054
Row 9-48 Column G - Fuel Type
 Since Column F includes Electric Drive, this column should allow electricity as a "fuel." Include Electricity as an option in the pull down list.
EPA has added "Electricity" as a fuel type.
-0046
Sub-Section 2. General Compressor Information  -  Complete for each Compressor
"Fuel Type"
 This should be deleted from the form all together, fuel type does not impact the methane emissions from a compressor.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

-0054
Row 9-48 Column H - Emissions Tier
 It is not clear what emissions tiers are referred to here. The purpose is unclear; generally, the Proposed ICR is concerned with the compressor not the driver. EPA should provide further clarification in the final ICR and explain the purpose of this request.
 Clarify; eliminate requirement for natural gas-fired engines (and other engines using fuel other than diesel).
EPA has clarified that "Emission Tier" is found from 40 CFR 98 Subpart C reporting data for each engine.
-0046
Sub-Section 2. General Compressor Information  -  Complete for each Compressor
"Emissions Tier"
 Is column H is asking for the site-wide emissions tier or engine emission tier? If engine tier, this would refer to diesel engines (compression ignition) and not natural gas driven engines. If this column was only intended to apply to compression ignition engines only, the column should be blacked out when anything other than compression ignition is selected as the engine type.
EPA has clarified that "Emission Tier" is found from 40 CFR 98 Subpart C reporting data for each engine.

EPA has corrected Table 2 to black out "Emission Tier" for spark ignition engines.
-0054
Row 9-48 Column M - Were direct emissions measurements made for compliance with the GHGRP in 40 CFR part 98, Subpart W?
 Column headings M-Q invite confusion, so EPA should simply request operating time in modes. If Q is yes, then EPA should populate using Subpart W data.
 If the answer is "yes" then the EPA should populate the Operating Time Fields. If the answer is "no," then column N should be negated.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

-0046
Sub-Section 2. General Compressor Information  -  Complete for each Compressor
"Were direct emissions measurements made for compliance with the GHGRP in 40 CFR part 98, subpart W? If no, please provide the total time the compressor was in standby-pressurized mode in RY2015."
 Specify that the time frame of the direct emissions measurements question is 2015.
 The availability of run time in standby pressurized and depressurized modes at sites not subject to 40 CFR Part 98 Subpart W in reporting year 2015 will most likely not be available as it is not required to be tracked and does not provide beneficial data to operators for optimization or maintenance.
EPA has specified the reporting year for each column.

Companies should provide best available data when responding to the ICR.
-0054
Row 9-48 Column O - If no, please provide the total time the compressor was in operating-mode in RY 2015. (hours)
 Columns O-Q can be simple requests for operating time in mode. However, if this is not a Subpart W applicable facility, then this information is not readily available and there will be a high cost associated with gathering this information.
 Per item above (row 9-48, column M), negate this field (black out) for non-Subpart W facilities. Rephrase question: "Total time in operating mode in RY 2015 (hrs)" and prepopulate with Subpart W data.
 If retained, allow engineering estimate for facilities that do not report under Subpart W.
Companies should provide best available data when responding to the ICR.
-0054
Row 9-48 Column P - If no, please provide the total time the compressor was in standby-pressurized-mode in RY 2015 (hours)
 Columns O-Q can be simple requests for operating time in mode. However, if this is not a Subpart W facility, then this information is not readily available and there will be a high cost associated with gathering this information.
 Negate for non-Subpart W facilities. Rephrase question: "Total time in standby-pressurized mode in RY 2015 (hrs)" and pre-populate with Subpart W data.
 If retained, allow engineering estimate for facilities that do not report under Subpart W.
Companies should provide best available data when responding to the ICR.
-0054
Row 9-48 Column Q - If no, please provide the total time the compressor was in not-operating-depressurized mode in RY 2015 (hours)
 Columns O-Q can be simple requests for operating time in mode. However, if this is not a Subpart W facility, then this information is not readily available and there will be a high cost associated with gathering this information.
 Negate for non- Subpart W facilities. Rephrase question: "Total time in not-operating-depressurized mode in RY 2015 (hrs)" and pre-populate with Subpart W data.
 If retained, allow engineering estimate for facilities that do not report under Subpart W.
Companies should provide best available data when responding to the ICR.
-0068
Remove the following questions from Table 2:
 Number of reciprocating compressors at the facility
 Number of centrifugal compressors at the facility
 If yes, identify the compressor sources controlled/recovered.
 If yes, what types of controls?
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

-0068
Add "Are the starter motors electric or gas driven?" to Table 2.
EPA appreciates the comment and will implement as suggested.

Table 3: Direct Emissions Measurements

-0054
Row 51
 Measurements are associated with an emission source, but there is no column for specifying the equipment type measured (e.g., rod packing, blowdown valve, unit isolation valve, etc.) Add column for this data element.
EPA has amended Table 3 to include "Point of Measurement."
-0054
Row 51 Column G/H - Emission Rate (scf/hr)
 Units are noted in row 52, and should not be in row 51.
EPA appreciates the comment and will implement as suggested.
-0068
Add the following questions to Table 3:
 Point of Measurement
 Volume % CO2 in emissions stream, if available
 Volume % VOC in emissions stream, if available
Split table by Point of Measurement (Blowdown Vent Stack(s) and Seal Vent Stack(s))
EPA has amended Table 3 to include "Point of Measurement."

Table 4: Centrifugal Compressor Specific Information

-0046
EPA should not assume that existing wet seal compressors can be converted to dry seal compressors, and should therefore collect information about whether it is technically feasible. As an optional reporting option, respondents should be allowed to provide a cost estimate for doing the conversion
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 67 Column D - If wet seals were replaced with dry seals on or after 1/1/2010, provide the cost. ($)
 Cost definition required. For example, does the cost include both equipment and labor?
EPA has amended this table to clarify the need for total cost (both equipment and labor).
-0068
Add the following questions to Table 4:
 Compressor suction pressure (psig)
 Compressor discharge pressure (psig)
 How many vents are connected to the seal oil separator(s)?
 How many vents are connected to the seal oil sump/ tank?
 Is seal oil separator vent(s) open to atmosphere or routed to suction or captured for other use?
 If captured for other use, state where the gas is routed
 Is seal oil tank vent(s) open to atmosphere or flared or captured for other use?
 If captured for other use, state where the gas is routed
 Seal oil circulation rate
 Seal oil pressure
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Table 5: Reciprocating Compressor Specific Information
-0046
The form should ask about rod replacement (versus rod packing replacement), programs to monitor and manage compressor emissions, and whether low emissions packing technology is used.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Unclear if owner/operators should leave the `Date of last rod packing replacement' field blank for new compression
EPA has amended this table to clarify that "N/A" should be selected if rod packing has not been replaced, which will negate the cost field.  EPA has also amended this table to request "Hours Since Last Rod Packing Replacement."

EPA has amended Table 2 to request "Date of Installation" for each compressor.
-0054
Row 76 Column B - Date of last rod packing replacement
 A new rod packing seal may not yet have been replaced; allow n/a and trigger a negation of the cost field.
EPA has amended this table to clarify that "N/A" should be selected if rod packing has not been replaced, which will negate the cost field.

-0054
Row 76 Column C - Cost of last rod packing replacement ($)
 Cost definition required. For example, Equipment and Labor.
 A new rod packing seal may not yet have been replaced; therefore, include "or installation" to this header.
 "Cost of last rod packing replacement or installation ($)." Clearly indicate that respondents may provide an engineering estimate.
EPA has amended this table to clarify the need for total cost (both equipment and labor).

EPA has amended this table to clarify that "N/A" should be selected if rod packing has not been replaced, which will negate the cost field.

Companies should provide best available data when responding to the ICR.
-0061, 59
In Table 5. Reciprocating Compressor Specific Information, under `Frequency of rod packing replacement', update the pick list to the following options:
 Never
 Semi-Annually
 Annual
 Bi-Annual
 Less Frequent than Bi-Annual
 Based on operating hours (company maintenance procedure),
 Based on leakage indicator (company maintenance procedure), and
 Per compliance with applicable regulations.
EPA has amended this table to allow for more options in the "Frequency of rod packing replacement" picklist.
0046
The `Frequency of rod packing replacement' drop down should include more options or include an "other", as the current options are very limiting. For instance, many replacements are based on run hours, or other factors, such as when high rod packing vent rates are observed.
EPA has amended this table to allow for more options in the "Frequency of rod packing replacement" picklist.
-0054
Row 77-82 Column D - Frequency of rod packing replacement
 Include "other" as an option in the pull down, and a column to specify. For example, the NSPS Subpart OOOOa criteria is 26,000 operating hours or 36 months.
EPA has amended this table to allow for more options in the "Frequency of rod packing replacement" picklist.
-0061
EPA should add a new column to Table 5. Reciprocating Compressor Specific Information for `Approximate operating hours between replacements.' Compressors may not run full-time and this will allow an operator to optionally specify replacing packing based on operating hours, either per company policy or per applicable regulations.
EPA has amended this table to request "Hours Since Last Rod Packing Replacement."
-0068
Add the following questions to Table 5:
 Is rod packing replacement based on a fixed schedule or emissions rate?
 If based on emissions rate, emissions threshold to trigger replacement (scf-CH4/hr)
 If based on emissions rate, frequency of measurement (months)
 If based on emissions rate, frequency of measurement (hours of operation)
 Frequency of rod packing replacement (months)
 Frequency of rod packing replacement (hours of operation)
 Number of compressor stages
 Suction pressure of stage 1 (psig)
 Discharge pressure of stage 1 (psig)
 Suction pressure of stage 2 (psig)
 Discharge pressure of stage 2 (psig)
 Suction pressure of stage 3 (psig)
 Discharge pressure of stage 3 (psig)
 Suction pressure of stage 4 (psig)
 Discharge pressure of stage 4 (psig)
 Rod packing material type
 Number of cups in the rod packing
 Number of rings in each cup
 Is the rod packing vent gas captured?
 If captured, state where the gas is routed (sales, for use on site, flared, other)
 EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Other/General

-0066
EPA should specifically request submission of any HAP emissions testing data submitted by the responder to another agency as a requirement of state or local permits, or as a result of a compliance or enforcement action.
EPA has amended the ICR to request information on additional air toxics, when applicable.
-0066
EPA must ensure that any HAP emission estimates utilizing data collected as part of the ICR are based on the most up-to-date emission factors that include all the relevant HAPs beyond BTEX.
EPA appreciates the comment and will be using the most current emission factors.
-0046
EPA should exclude vapor recovery compressors from this ICR. Vapor recovery compressors similarly operate at low pressures and/or low volumes.  EPA must at least add a column to Sub-Section 2 for "Operational Service" with selection options of "Process Gas, Vapor Recovery, Refrigeration, Other".
Vapor Recovery compressors should be included in Compressor service.

Add Operational Service Column.
-0046
EPA should provide a compressor driver horsepower threshold, below which, the compressor would not have to be included in the ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Blowdown Tab

Table 1: Facility Information

-0027
Add category "Blowdowns associated with the storage field (outside the compressor station)" to avoid confusion or lack of information from storage operations.  Make this consistent with Subpart W to avoid undue burden.
 EPA appreciates the comment and will implement as suggested.
-0054
Row 5-12 Column B-J - Blowdown information
 These fields are included in Subpart W for compressor stations and should be prepopulated by the EPA if the facility is subject to Subpart W reporting.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
"Cumulative volume of natural gas blown down (scf)"
 Request `pre-control' be added beforehand for clarity.
EPA appreciates the comment and will implement as suggested.
-0046
The category "Recovered for sale" is confusing. A common practice is for the majority of gas in a compressor to be routed back into the process (usually to the facility inlet), and then the small amount of gas remaining in the compressor is blown down. This would not necessarily be considered "recovered for sale." EPA should simply title this category "Recovered."
For the purposes of this ICR, "recovered for sale" means that the gas is routed back into the process.
-0054
Row 14-22 Column A-D - Hot taps or other practices
 If used, these "practices" most likely apply for pipeline and not the compressor stations, etc. Clarification of action is needed. Example operations could include: isolating customers to conduct a maintenance blowdown; taps for new costumers or suppliers. What is covered by this item?
 Black out these cells if Compressor station, storage, etc. is selected. Should only be filled in if "Pipeline" facility.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 19 Column A - Use pipeline pump down techniques
 Include option of "Recompression with Multiple Lines" as an additional row. This option is different from "Use pipeline pump down techniques."
EPA appreciates the comment and will implement as suggested.
-0054
Row 20 Column A - Use flexible membrane liners (pipelines)
 Include option of "Mechanical or Composite Sleeve" as an additional row. This option is different from "Membrane Liners." The "unit of measure" is not clear and "miles of pipe" should be replaced with "number of events" for mechanical or composite sleeves.
EPA appreciates the comment and will implement as suggested.
-0054
Row 21 Column A - Inspect/repair leaking (not fully sealed) PRD and blowdown valves
 This is a "leak" question (i.e., valve not sealed) and not a "blowdown" event question. In addition, inspection and repair frequency may differ.
 Delete question (Leaks are addressed in other form). If retained, move this to the equipment leaks form. Differentiate frequency of inspection and frequency of repair.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
"Inspect/repair leaking (not fully sealed) PRD and blowdown valves"
 The spreadsheet requests `Frequency.' EPA should clarify is whether this is the frequency of inspection, repair, or both.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 22 Column A - Other (specify)
 Need an entry field to specify the type of "other."
EPA appreciates the comment and will implement as suggested.
-0068
Add the following questions to Table 1:
 If yes, provide the operator pressure of the equipment: Facility piping (except gathering or transmission pipelines).
 If other method used, specify method.
 If yes, provide the operator pressure of the equipment: Gathering or Transmission Pipeline venting.
 If other method used, specify method.
 If yes, provide the operator pressure of the equipment: Compressors.
 If other method used, specify method.
 If yes, provide the operator pressure of the equipment: Scrubbers/strainers.
 If other method used, specify method.
 If yes, provide the operator pressure of the equipment: Pig launchers and receivers.
 If other method used, specify method.
 If yes, provide the operator pressure of the equipment: Emergency shutdowns (regardless of equipment).
 If other method used, specify method.
 If yes, provide the operator pressure of the equipment: Other equipment not specified.
 If other method used, specify method.
 Cost of hot taps per event ($)
 Cost of pipeline pump down per event ($)
 Cost of flexible membrane liners (pipelines) per event ($)
 Cost of inspection/repair of leaking (not fully sealed) PRD and blowdown valves per event ($)
 Cost of other (specify) per event ($)
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Other/General

-0061
EPA should explicitly allow for engineering estimates to be applied for sources collecting blowdown data (i.e. Subpart W) and should not require estimates for those facilities that have not collected data.
Companies should provide best available data when responding to the ICR.
-0046
Many facilities are not currently required to track blowdowns and otherwise, have no reason to do so. Facilities newly subject to Subpart W will be reporting blowdowns for the first time in 2017, and can use BAMM for 2016 blowdown calculation inputs. Thus, EPA should add a note that best available/engineering estimates are allowed for all items on this tab where data is not actually tracked.
Companies should provide best available data when responding to the ICR.
-0048
While most operators will likely certify that blowdowns occurred at some time during 2015, that may be the only information known. We are unaware of any state or federal regulations requiring oil and natural gas operators to keep records of blowdown events or cumulative volumes for oil wells.
Companies should provide best available data when responding to the ICR.
-0061, 46
The definition of blowdowns should exclude de minimis reporting consistent with B.40 CFR Part 98, Subpart W.
The ICR should follow the GHGRP and exclude all blowdowns of equipment that is less than 50 actual cubic feet.
Companies should provide best available data when responding to the ICR.
-0061
Blowdown events routed to atmosphere or a flare should be the only events for which EPA is requesting data. Equipment depressurization events that are not released to atmosphere or routed to a flare do not provide meaningful information for evaluating emission impacts and should not be included within scope of the ICR.
EPA has amended the definition of "Blowdown" to clarify that equipment depressurization events that are not released to atmosphere or routed to a control device are not to be included in the ICR.
-0061
For pipeline blowdowns, it is unclear which pipelines or sections of pipelines would be required to be reported for a facility. Pipelines can span great distances and connect gathering and boosting to gas processing. To parse out the pipeline blowdowns for a specific facility would not be a straightforward data collection.
EPA has amended Table 2 to request blowdown information from all Transmission Pipeline Facilities and Gathering and Boosting Facilities per the definitions provided in the ICR.
-0058
Blowdown reporting should apply only to "Natural Gas Transmission Pipeline Facilities."
EPA has amended Table 2 to request blowdown information from all Transmission Pipeline Facilities and Gathering and Boosting Facilities per the definitions provided in the ICR.
-0046
Blowdowns are only routed to atmosphere, flare, or back to the process. GPA Midstream is not aware of blowdowns being routed to a thermal oxidizer, incinerator, or used as fuel.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
EPA should ask whether operators keep records of blowdown events for the various equipment types. If the answer is "yes," then the additionally requested information should switch from black to a cleared cell where the information can be provided.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Only Blowdown reporting should be required for Transmission Pipeline Facilities in the Part 2 survey as the 2015 amendments to the GHGRP focus on pipeline blowdown emissions only.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

ControlDevice Tab

Table 1: Facility Information

-0054
Row 3 Column A - Number of control devices at the facility
 The intro page describes a control device as a flare, incinerator or vapor recovery unit. Control device is not defined on the definitions page. Definition required to answer "number of devices." Clarify "or other add-on control devices."
EPA has amended the Definitions Tab to include "Control Device."

Table 2: General Control Device Information

-0054
Each control device is employed with a piece of equipment as a system. The context or application of a control device is essential to assessing the control device. Include information on the reason for the device installation and the equipment it is tied to.
EPA has amended each tab in the ICR to allow equipment to be linked to a control device listed in the ControlDevice Tab.
-0054
Change Heading to "2. General Control Device Information - Complete for each Control Device/Equipment Pairing:"
EPA has amended each tab in the ICR to allow equipment to be linked to a control device listed in the ControlDevice Tab.
-0061
EPA should use waste gas in lieu of natural gas when referring to the control device feed gas in Table 2. General Control Device Information.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
EPA should delete `Release height' and `Stack diameter' from Table 2. General Control Device Information.  This data is only a small fraction of the information needed to accurately determine ground level concentrations.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
Tab includes request for "Typical NG Flow to Device." EPA should define what "typical" means. Recommend revising this request to average flow rate over the last 30 days.
EPA has amended Table 2 to remove "Typical NG Flow to Device."
-0061
EPA should remove `Fraction of time control device is operated (lit) while NG flow is present' from Table 2. General Control Device Information. It is unclear what "fraction of time" is being requested.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061