Oil and Gas ICR Comment Summary
                                  Comment ID
                                Comment Summary
                           EPA Response/Action Taken

Timing

-0008, 9, 10, 11 (dup 16), 13 (dup 17), 15, 18, 35, 53
Requested more time (either 30-days or 60-days) to comment on the ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0007, 21, 27, 28, 29, 30, 31, 34, 35, 36, 40, 41, 42, 45, 46, 48, 49, 50, 51, 52, 54, 58, 59, 60 (dup 62), 61, 65, 70
Request for more time to respond to each part of the ICR.  Reasons include:
 Location and consistency of data across several databases and hard copy records
 Data collection and sampling efforts
 Inclement weather during field work
 Avoid overlap with GHGRP and permit compliance reports
 Avoid winter heating season where personnel are already stretched thin
 EPA's intent to mail Part 1 will reduce response time
 Significant field work and travel time on respondents
 Holiday seasons, personnel vacations
 Operators have more than 30 facilities
 Due to the need to hire contractors to complete this work, need additional time to draft contracts/get contracts in place
 Using the same system for both the ICR responses and the GHGRP reporting risks overloading the e-GGRT system and the third-party help desk contracted by EPA.
 Industry is generally not familiar with the CARB sampling methodology, a method, as discussed infra, that is not typically used by the laboratories relied on for analysis.
 Extend deadline to allow sufficient time for the agency to compile a representative sampling pool for gathering and boosting stations.
 October 30th is not a business day.
While EPA acknowledges commenters' concerns with completing the ICR within the required timeframe, the response deadline will remain at 30 days (Part 1) and 120 days (Part 2) past receipt of the final ICR (see Comment Response Memo).
-0021, 27, 28, 29, 30, 31, 34, 36, 40, 41, 46, 48, 49, 50, 51, 52, 54, 58, 59, 60 (dup 62), 61, 65, 70

Requested Time Frames:
-0028, 29, 30, 48, 49, 51, 61 = Allow 180 days to respond to both parts of the ICR.
-0070, 46, 52 = Allow 240 days to complete both parts
-0050 = Allow 60 days for Part 1.
-0036 = Allow 90 days for Part 1.
-0040 = Allow 60-120 days for Part 1
-0034 = Extend Part 1 deadline to February 27, 2017.
-0021, 41 = Allow 180 days for Part 1 (April 2017).
-0036, 40, 50, 59 = Allow 180 days for Part 2 (April 2017).
-0021, 27, 31, 34, 54, 58 = Extend Part 2 deadline to June 2017 (8 months).
-0041 = Allow 1 year for Part 2.
While EPA acknowledges commenters' concerns with completing the ICR within the required timeframe, the response deadline will remain at 30 days (Part 1) and 120 days (Part 2) past receipt of the final ICR (see Comment Response Memo).
-0028, 36, 48, 59
ICR should be conducted in two separate phases; Finish Part 1 and learn from it to create final Part 2.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0028, 29
EPA/OMB does not have enough time to analyze all of the submitted comments.
EPA has analyzed all submitted comments to the Oil and Gas ICR.
-0028, 29, 30, 48, 51, 59
Deadlines for both Part 1 and Part 2 should be the same, as any analysis of the ICR will incorporate both Part 1 and Part 2 data.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0035
ICR was published on the same day as final OOOOa, which did not allow for full industry engagement on the ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0037, 39, 43, 47, 55, 56
EPA should work move as quickly as possible to gather data through the ICR.
The response deadline will remain at 30 days (Part 1) and 120 days (Part 2) past receipt of the final ICR (see Comment Response Memo).
-0036
Clarify whether the surveys will be sent simultaneously.
Part 1 and Part 2 of the ICR will be sent simultaneously.
-0046, 52
EPA should delay the Part 2 ICR surveys at least until after companies report gathering and boosting facilities under the GHGRP in March of 2017. Doing so will provide EPA a more comprehensive list of gathering and boosting companies.
While EPA acknowledges commenters' concerns with completing the ICR within the required timeframe, the response deadline will remain at 30 days (Part 1) and 120 days (Part 2) past receipt of the final ICR (see Comment Response Memo).
-0020, 36
Postpone the ICR until after OOOOa information is received and evaluated.
While EPA acknowledges commenters' concerns with completing the ICR within the required timeframe, the response deadline will remain at 30 days (Part 1) and 120 days (Part 2) past receipt of the final ICR (see Comment Response Memo).

Burden Estimates

-0007, 21, 28, 29, 35, 36, 40, 41, 42, 45, 46, 48, 49, 50, 51, 52, 54, 58, 59, 60 (dup 62), 61, 65, 70
ICR will be burdensome / more burdensome than projected
Part 1 ICR cost/time estimate is low.  Reasons include:
 Insufficient time assumption per operator
 Underestimated time/cost for EPA to review submitted materials
Part 2 ICR cost/time estimate is low.  Reasons include:
 Calculation error in Total Labor Cost/Activity
 Underestimated cost of tank liquid sampling and analysis (at least $2600/sample)
 Did not include costs associated with internal database modifications that will be required to comply with the ICR
 Did not include costs associated with the increased personnel hours needed to obtain the information
 Underestimated hours per facility (should be 15-25)
 EPA does not consider the planning, travel and other logistical requirements to complete field visits
 The analysis fails to consider that technical expertise (e.g., third parties) may be required to execute these activities in many cases.
 The definitions and equipment categories inconsistencies with Subpart W definitions will preclude the use of existing data and associated processes for data collection, require a new effort to understand the applicability of the revised definitions and categories, and require operators to implement a program to gather the data.
 Estimate for reading/understanding instructions is too low
 EPA underestimates the prevalence of equipment at T&S segment facilities.
 EPA underestimated the time required for equipment leaks (Collection activity 2H), blowdown events (2I), pneumatic counts (3A), and equipment counts (3B).
 Two separators and four tanks are an appropriate estimate for the gathering and boosting ("G&B") sector. It is not appropriate to assume that there are the same number of separators and tanks at processing facilities as there are at G&B sites.
 EPA is failing to take into account the varying number of pneumatic devices per site
 Less than half of G&B sites will have an AGRU on site. EPA's estimate that half of the processing sites will have AGRUs is reasonable.
 EPA's estimate that half of the G&B sites will have a dehydrator unit is an underestimate.
 EPA's estimate of one dehydrator per processing site is an underestimate.
 EPA does not specify what the makeup is of the four compressors assumed to be at a site. EPA should clarify whether it is four reciprocating compressors, four centrifugal compressors, or a combination of both. GPA Midstream estimates that 10 compressors per processing plant is a more appropriate estimate.
 Using the same basis for all industry sectors is inaccurate, as it does not accurately reflect differences among sectors.
 One flare and one vapor recovery unit ("VRU") may be an appropriate estimate for the G&B sector, but the same estimate is not appropriate for processing.
 Actuation Consumption Rate is not known or readily available. EPA only estimated 0.5 hours of instrument tech time and 0.5 hour of engineer time per actuator in overall burden estimates which significantly underestimates the level of effort required to complete this information and is unrealistic for the effort involved for data collection.
General reasons:
 Should be reevaluated to include cost for facilities that are not automated or that do not have remote monitoring
 Did not include additional time for data validation
 Contractor costs, especially if many operators are trying to hire the same contractors
 Did not include additional time for e-GGRT submittal
EPA must consider that burden and provide adequate additional time for recipients operating more than 500 facilities to provide the response to the ICR.
EPA has revised the burden estimate to reflect all changes to the ICR.
-0029, 40
Cost could be reduced by reducing number of operators being required to submit information.  Within EPA's statistical review, EPA data indicated that statistically reliable information could be acquired with 1/7[th] the number of surveys.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0031
EPA underestimated time and cost required for the field physical counts of all equipment components >5 wt % of any VOC, CH4, CO2 at each facility.  Actual time ranged from 20-40 hours/facility. Total cost could range up to $4,500/facility.
EPA has revised the burden estimate to reflect all changes to the ICR.
-0040
Sampling and analysis of feed material was not included in the time and cost estimates in any states except California.
EPA has included sampling and analysis for all states in the burden estimates.
-0050, 49
Modify both cost and time burden for completing the equipment leak survey.  LDAR requirements do not currently apply to all operators across all jurisdictions, and many who are subject to LDAR are not collection certain types of the information requested. This would require additional costs, such as hiring and training contractors, transportation of OGI equipment to new locations, and compensating employees needed to conduct the surveys.
EPA is requesting data from previous leak surveys to be provided in Part 2 of the ICR.  EPA is not requiring facilities to complete any additional leak surveys.
-0064, 59
EPA needs to provide information supporting the validity of their assumption of two wells per facility. The assumption of two wells per facility is grossly underestimated, therefore the corresponding burden and costs would also be vastly understated.
EPA based the assumption of 2 wells per facility from the NSPS OOOOa technical support document. We have revised the definition of facility for production facilities, referred to as the "well site facility" to be similar to the well site definition in NSPS OOOOa.  The well site facility consists of a well surface site and its centralized production surface site. By aligning the facility definition for production facilities with the well site definition in NSPS OOOOs, we consider the analysis conducted to establish the average of two wells well site to be directly applicable to the impact estimates for this ICR.

Statistical Sampling Approach

-0061
Support for a modified GOR approach for Part 2:
 Add "Stripper Wells with low production"
 Increase margin of error for populations with low variability from 10% (suggested 20% or 30%)
 Allowing a voluntary process for operators to correct contact information, therefore reducing the need to arbitrarily increase the number of ICRs mailed above the statistical estimates (see mailing list comment)
EPA has amended the statistical sampling approach to include "Stripper wells, production <= 15 BOE/day." See Comment Response Memo for more information.

EPA will allow operators to review and correct contact information prior to sending out Part 1 and Part 2 of the ICR.  Operators should visit https://oilandgasicr.rti.org/ before October 30, 2016 to make any necessary corrections.
-0038
The population distribution is skewed and better modeled as log-normal rather than Gaussian. A relatively small number of sources contribute a large fraction of the emissions. With a heavy-tailed distribution that is skewed to the right, use of the population median multiplied by the total number of facilities will substantially underestimate total sector emissions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0038
Based on the Proposed ICR, it appears that there will be a single parameter selected from each population subgroup for which a mean value will be computed. ODEQ requests clarification as to which parameter EPA is investigating. If more than one parameter is being investigated, ODEQ is requesting additional clarification of the statistical approach.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0038
Although the arithmetic mean is the appropriate measure for use in scaling emissions to estimate sector-wide emissions (a bottom-up estimate), the skewed nature of the distribution makes it likely that the standard deviation of the mean wellhead facility GHG emissions will be found to exceed the mean emission rate. This property is mentioned in the Supporting Statement where the ratio of the standard deviation to the mean value was assumed to be 3, because "emission values often vary over 4 to 5 orders of magnitude". Supporting Statement for Public Comment: Information Collection Effort for Oil and Gas Facilities (2016) at 21. Use of standard statistical descriptors like the mean value +/- standard error (with symmetrical error bars) may yield a negative value for the low end of the range. This is impossible, because facility GHG emissions must be zero or positive.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0038
No more than 5% of the total number of detailed surveys should target wells drilled in 2011 or later. A substantial number of emission units (e.g., tanks, pneumatic devices, etc.) located at facilities associated with wells completed after August 23, 2011 are subject to New Source Performance Standards. In some state programs, these wells are permitted and have been inventoried in detail as point sources, with the emissions from those facilities well characterized.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0038
Samples should be stratified in a two-tier approach: by the age of the wells (primary stratification) and by basin (second level of stratification). Gathering data on formation types would be helpful, but should not be used to stratify the population. Similarly, absolute production data (i.e., not just the GOR ratio) would also be gathered for each response to the detailed survey. EPA should target older wells for which little information is available.
EPA will sample based on the explained GOR approach. See Comment Response Memo for more information.
-0050
General support of stratification of operator population by geographical region for Part 2.  The regulatory environment is driven by region, not GOR range.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
For the T&S segments, due to the limited variability in the types of sources and operation, and/or availability of information through other regulatory programs, a smaller percentage of facilities will be sufficient to provide a representative sample, reducing the amount of resources needed to respond to the ICR and to analyze the information submitted.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Alternative approach:
 EPA categorize wells according to three broad factors -- well production level, whether a well reports to Subpart W, and the geological basin in which a well is located  --  and tailor its sampling approach to each category. Suggested approach results in 18 total strata that capture these distinctions.
 EPA consider using available emissions and production information to tailor the sampling approach for particular well types within each stratum:
 Non-marginal reporters  -  For this stratum, Subpart W provides information for each operator on average emissions per well. Therefore, we propose that EPA sample proportionally to average well emissions, which means higher emitters are more likely to be selected for the survey.
 Non-marginal non-reporters  -  For higher producing wells that do not report to Subpart W, EPA should sample proportionally to production.
 Marginal wells (both reporters and non-reporters)  -  The characteristics of marginal oil and gas wells may be different. For instance, marginal oil wells may not be connected to gas gathering infrastructure and so can have emissions from casing head gas, tank vapors, and equipment leaks. Also, neither GOR nor production is a good metric to tailor sampling from these sources.  For these reasons, we suggest simple random sampling from these strata.
 For the remaining industry segments, we do not propose additional stratification, although for certain segments, we recommend that EPA pursue an emissions-based sampling approach in which Subpart W provides additional data and distinct approaches where the universe of facilities is small or the agency is still in the process of collecting Subpart W information.
 For the Natural Gas Processing, Transmission, and Underground Storage strata, we recommend EPA pursue an emissions-based sampling methodology, leveraging facility-level data from Subpart W.
 For the Gathering and Boosting and Natural Gas Transmission Pipeline Facility strata, we support EPA retaining its proposed approach, focusing on simple random sampling.
 For LNG storage and LNG import/export facilities, due to the small population of facilities, we support EPA's proposal to perform a census -- that is, to include all facilities in the sample.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
EPA should develop a methodology to avoid disproportionately burdening a particular operator with an overwhelming number of requests.
The burden that a company experiences will be proportional to number of facilities that company operates. EPA is requesting a representative sampling of facilities, which will not necessarily be spread burden evenly across operators.
-0049
EPA should avoid oversaturating a particular region with requests which could lead to a flawed understanding of industry operations and economics.
EPA will be sure that each basin is sampled proportional to the number of wells in each GOR range for each basin (proportioning method is described in the ICR Supporting Statement).
-0049
Alternative Option:
Rather than guessing at what might be representative based on GOR or basin, we recommend that EPA base its selections on the Part I ICR responses. By analyzing that information, EPA will have a much better understanding of how to target Part II requests. It strikes us as a missed opportunity for EPA not to leverage the valuable information it is collecting under Part I, and is another reason the Part II data collection should occur after and not simultaneous with Part I.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
EPA should limit its request to areas designated in attainment or unclassifiable under the current Ozone National Ambient Air Quality Standard. This will facilitate EPA avoiding duplicative or confusing requirements for existing sources in nonattainment areas that are already regulated by states.
EPA is requesting information in both attainment and non-attainment areas to accurately account for all oil and gas operations in the country.
-0046
GPA Midstream requests clarification about whether the final sampling size will be adjusted once a more accurate number of facilities is established.
EPA will continue to employ the same method for determining sample size no matter what the population is. We also note that the number of facilities selected is quite independent of the actual number of facilities in the population when that population is large and it is the large industry segments with very large numbers of facilities where we have the greatest uncertainties in the number of facilities, so the number of samples from these population s is not expected to vary.
-0052, 46
EPA has not properly characterized the facility count for oil and gas industry sources. There is a high probability that EPA has under-counted facilities in the gathering and boosting segment.  EPA should delay the ICR process pending EPA's collection of more accurate facility count data through the implementation of new GHGRP provisions applicable to the gathering and boosting sector
While EPA acknowledges commenters' concerns with completing the ICR within the required timeframe, the response deadline will remain at 30 days (Part 1) and 120 days (Part 2) past receipt of the final ICR (see Comment Response Memo).

Mailing List

-0049, 61
EPA should establish a voluntary process for operators to identify/correct the preferred contact prior to releasing the ICR.
EPA will allow operators to review and correct contact information prior to sending out Part 1 and Part 2 of the ICR.  Operators should visit https://oilandgasicr.rti.org/ before October 30, 2016 to make any necessary corrections.
-0027
Publish preliminary list of target facilities as part of next ICR public comment period.
EPA will allow operators to review and correct contact information prior to sending out Part 1 and Part 2 of the ICR.  Operators should visit https://oilandgasicr.rti.org/ before October 30, 2016 to make any necessary corrections.
-0054, 58
EPA should mail or email each ICR letter to the appropriate company e-GRRT Designated Representative for the company that operates the facility targeted by the ICR. This will increase the probability of a high response rate to the ICR letters.
EPA will allow operators to review and correct contact information prior to sending out Part 1 and Part 2 of the ICR.  Operators should visit https://oilandgasicr.rti.org/ before October 30, 2016 to make any necessary corrections.
-0054
EPA include an interim review step to assess equitable distribution of burden for all affected companies  -  i.e., a proportionate share of ICR letters.
The burden that a company experiences will be proportional to number of facilities that company operates. EPA is requesting a representative sampling of facilities, which will not necessarily spread burden evenly across operators.
-0054
EPA should consider developing a stakeholder group to develop "model facilities" and related information that can be used to assess equipment, emissions, and reduction opportunities.
EPA will consider use of "model facilities" once the ICR data has been received.
-0049
EPA should clarify that any party receiving either part is only required to respond and provide information for wells where it is the operator.
EPA will allow operators to review and correct contact information prior to sending out Part 1 and Part 2 of the ICR.  Operators should visit https://oilandgasicr.rti.org/ before October 30, 2016 to make any necessary corrections.

Part 1 Questionnaire

Instructions

-0061
Update Part 1 instructions to include:
 Clarify how/if wellhead only sites are connected to facilities
 Scope of the Part 1 ICR should be limited to 2015 calendar year data
EPA has added definitions of "Well surface site" and "Centralized production surface site" to the ICR and removed the definition of "Facility" from Part 1 to provide clarity.

EPA is requiring best available data as of November 1, 2016.
-0050, 49
Clarify that EPA is seeking information only on those wells operated by the company so as to eliminate duplicate reporting from both owner and operator.
EPA will allow operators to review and correct contact information prior to sending out Part 1 and Part 2 of the ICR.  Operators should visit https://oilandgasicr.rti.org/ before October 30, 2016 to make any necessary corrections.
-0050, 49, -0064

EPA should better define its scope so as to make clear whether it intends to include facilities that are connected but not collocated (and vice versa).

EPA has added definitions of "Well surface site" and "Centralized production surface site" to the ICR and removed the definition of "Facility" from Part 1 to provide clarity.

Table 1: Parent Company General Information

-0049
a. General Facility Information
 Employee counts are not useful to EPA from an emissions perspective. Therefore it is recommended that EPA strike this request from the ICR.
 Alternatively, EPA should instead focus on whether the respondent is a small business in order to more easily quantify the impact of the ICR on small businesses. To accomplish this, it is recommended that EPA indicate that the Small Business Administration's definition of a small entity is 1,250 employees excluding contractors and ask respondents to indicate whether they fall under this definition.
EPA has amended Table 1 to request "Average Number of Employees" and has provided a picklist of employee number ranges.

Table 3: Facility Description

-0061
Add basin level reporting to Part 1.  Include the following:
 Basin Identifier
 Number of manned onshore well sites in basin
 Is electrification from grid power available in basin?
 Approx. number of wells that have access to gas infrastructure in basin
Move "Is facility manned?" to basin level reporting (see above comment).
Move "Does the facility have electricity?" to basin level reporting (see above comment).
EPA has removed "Is the Facility Manned?" and "Does the facility have electricity?" from Part 1 of the ICR.
-0061
If an operator owned the facility on December 31, 2015 then that operator would report readily available information for Part 1, as records and data are not typically available in a format that allows for a timely response after a purchase of an asset.
 Step 3 should be modified to remove reference to `managed' assets. Only the owner and operator as of December 31, 2015 should be required to report for Part 1 information. This will eliminate confusion for facilities with multiple operators and clarify who is responsible for reporting facilities that have joint owners, which are operated by one of the owners.
EPA is requiring best available data as of November 1, 2016.
-0050
Clarify whether EPA considers temporary generators to be connected to the electrical grid.
EPA has removed "Does the facility have electricity?" from Part 1 of the ICR.
-0050
Clarify what encompasses the electrical grid within the proposed ICR.
EPA has removed "Does the facility have electricity?" from Part 1 of the ICR.
-0049, 48
Recommend instead that EPA make availability of electricity part of its Part 2 request.
EPA has removed "Does the facility have electricity?" from Part 1 of the ICR.
-0049, 48
Recommend that EPA clarify that facilities not connected to the electrical grid but merely using temporary generators not be considered electrified. These generators do not necessarily remain onsite and may not have the capacity to operate instrument air pneumatic systems or other systems.
EPA has removed "Does the facility have electricity?" from Part 1 of the ICR.
-0061
Move "Distance from facility to field office (miles)" to Part 2
EPA has removed "Distance from facility to field office (miles)" from Part 1 of the ICR.
-0021, 61
In requesting the distance that a facility is from to a field office, is this the distance as the crow flies or the driving distance?
EPA has moved "Distance from facility to field office (miles)" from Part 1 of the ICR to Part 2.  Distances should be measured as driving distance.
-0050, 49, 48, 59
Provide explanation on why "distance from facility to field office" is necessary to regulate methane and VOC emissions from O&G industry.
 An employee or contractor will not travel to a facility, back to the field office, then on to the next facility, and so on, but will instead visit several facilities while away from the field office on a pre-planned route. Therefore, the distance to the nearest field office doesn't provide EPA with much insight into how field operations are conducted.
 Recommend that the distance be the shortest year-round driving distance between a field office and the facility which would allow EPA to gain a better understanding of how easily accessible a facility is on a year-round basis.
 EPA should have a pull down set of ranges that can be more simply answered (e.g., 0-10 miles, 10-25 miles, 25-50 miles, etc.).
EPA has moved "Distance from facility to field office (miles)" from Part 1 of the ICR to Part 2.  Distances should be measured as driving distance.  EPA has also added "How frequently is well site visited by field office personnel?" to Part 2 of the ICR.
-0050
Servicing staff is made up of a roving team of responders.  Many times these responders are responding from his/her own house or another location as opposed to responding directly from the field office.
EPA has moved "Distance from facility to field office (miles)" from Part 1 of the ICR to Part 2.  Distances should be measured as driving distance.  EPA has also added "How frequently is well site visited by field office personnel?" to Part 2 of the ICR.
-0061
Move "Distance from facility to nearest natural gas gathering line (miles)" to Part 2.
 The information should only be requested for oil wells with associated gas that are not connected to a gas gathering line.
EPA has moved "Distance from facility to nearest natural gas gathering line (miles)" from Part 1 of the ICR to Part 2.  EPA has clarified that this information should only be provided if well sites are not connected to a gathering and boosting or transmission pipeline.
-0021
In requesting the distance that a  facility is from the nearest gas gathering line, is this the distance as the crow flies or the distance of a feasible pipeline route to that gathering line?
EPA has moved "Distance from facility to nearest natural gas gathering line (miles)" from Part 1 of the ICR to Part 2.  EPA has clarified that this information should only be provided if well sites are not connected to a gathering and boosting or transmission pipeline. Distances should be measured as driving distance.
-0050, 49, 48, 59
Provide explanation on why "Distance from facility to nearest natural gas gathering line" is necessary to regulate methane and VOC emissions from O&G industry.
 All natural gas wells should be exempted from this requirement, as no rational operator would develop a natural gas well without takeaway capacity, and reporting the distance to gas gathering lines is not a worthwhile exercise.
 An oil well that is connected to gas gathering should simply be able to satisfy EPA with a yes or no answer.
 If an operator has an existing contract with a specific midstream operator to tie in all wells in an area to their pipeline, there may be a closer gathering line that the survey respondent is not going to connect to for contractual or logistical reasons. Reasons could include not having rights-of-way to connect to the closest gas gathering line, or having gas that is not of sufficient quality to connect to the nearest gathering line.
 Calculating distance to natural gas gathering lines creates a burden on respondents to locate irrelevant lines that far outweighs the useful benefit of this information. In many instances, operators are contractually obligated to use a particular midstream gas gathering company. Additionally, many marginal oil wells do not produce enough gas to warrant a midstream company to invest in gas gathering lines.
 A more appropriate question is whether the facility is connected to a natural gas sales line, rather than distance to the nearest gathering line.
EPA has moved "Distance from facility to nearest natural gas gathering line (miles)" from Part 1 of the ICR to Part 2.  EPA has clarified that this information should only be provided if well sites are not connected to a gathering and boosting or transmission pipeline.  EPA has also requested reasoning for any lack of connection.
-0064
From which point of the hundreds of wells, or other associated equipment, would one measure the distance to the nearest gathering line?
Facilities should measure the distance to the nearest natural gas transmission or gathering and boosting pipeline from the centroid of the wells.
-0050, 48
EPA should request information on whether a facility is connected to a natural gas sales line. (instead of distance to gathering line).
EPA has amended Part 2 of the ICR to request "Quantity of natural gas leaving the facility (sales) in the 2015 calendar year (thousand standard cubic feet)."
-0048, 49, -50, 59, 61
To reduce burden on operators to collect data that cannot inform a rulemaking and without an identifiable benefit, collecting liquids unloading data should be removed from Part 1.
 The mere occurrence of liquids unloading reveals little information of use to EPA, as it does not address the timing, frequency, technique, or other pertinent information about the process.
 The data in Part II would prove much more useful than the data in Part I. We encourage EPA to remove liquids unloading from Part I requirements.
 Liquids unloading will be highly variable over the life of the well and can change in response to shut-ins and other events.
 The regulation of liquids unloading is not suitable for a standard, industry-wide regulation.
EPA has removed the collection of liquids unloading data from Part 1 of the ICR.
-0021
In requesting whether wells conduct liquids unloading can EPA be more specific as to what they are looking for.  Oil wells are continually unloading liquids as a form of production.  Only dry gas wells do not unload liquids.
EPA has removed the collection of liquids unloading data from Part 1 of the ICR.
-0061
Is there a flare or thermal combustor present at the facility?' should be removed from the Part 1 ICR. The presence of a flare or thermal combustor is not a useful data parameter in the current format for Part 1 since the form does not identify the emission source that is controlled.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0067
EPA should refine its question in Part 1, Question 3 and replace with the following three questions:
:: Is there a flare present at the facility?
:: Is there an internal thermal combustor present at the facility?
:: Is there a vapor recovery unit present at the facility?
EPA has amended Part 1 of the ICR to include "Is there a flare or thermal combustor present at the surface site?"
-0068
Add the following questions to Table 3:
 Latitude and Longitude of facility
 If the facility is unmanned, how often does an operator visit the site? (Number of visits per year)
 Is this facility connected to a natural gas gathering line?
 Does this facility vent associated gas? If so, how much was vented in 2015?
 Does this facility flare associated gas? If so, how much was flared in 2015?
 Does this facility produce water?
EPA has amended Part 1 of the ICR to include "Latitude of surface site centroid (degrees decimal)" and "Longitude of surface site centroid (degrees decimal)."  Part 2 now has a more detailed question regarding whether a facility is manned. EPA has also added "Is there a flare or thermal combustor present at the surface site?" to Part 1 of the ICR.

Table 3: Equipment Counts

-0035
EPA is requesting the number of producing wells for a facility. Many wells are currently shut in due to the economic environment  -  the operating cost is greater than the revenue produced by the well. Does this count as a producing well? What time period should we consider for a producing well that has been shut in?
EPA has amended Part 1 of the ICR to request "Well Type" for each Well ID at a well surface site.
-0061, 48, -0035, 59, -0049
`Number of Capped or Abandoned Production Wells' should be removed from the ICR. Data for historically abandoned or capped wells may not be readily available, and in some instances, information may not exist.  Information on many `capped or abandoned wells' is unavailable due to divestitures, mergers, and bankruptcies. Furthermore, this information is not readily available on a per facility basis and will require a considerable amount of time to obtain.

Companies should provide best available data when responding to the ICR.

-0049
h. Number of Separators
 EPA should revise the request to specify whether a separator is two-phase or three-phase.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Add the following to the facility-wide equipment counts:
 Number of water tanks <10 bbl/day
 Number of water tanks >=10 bbl/day
 API gravity of hydrocarbon liquids going to the tank
 Number of pneumatic devices
 Number of dehydrators
 Number of flares
 Number of AGR units
 Number of heaters/treaters
 Number of headers
 Number of metering skids
EPA has amended Part 1 of the ICR to include number of dehydrators.

Table 3: Well Identification

-0061
Add Well Classification parameter to align with the sampling approach selected for Part 2.  API recommends the following categories:
 Dry Gas
 Wet Gas
 Coalbed Methane
 Associated Gas/Light Oil
 Heavy Oil
 Stripper
EPA has amended Part 1 of the ICR to request "Well Type" for each Well ID at a well surface site.

Other/General

-0021
EPA should be more specific regarding the information requested.  Specifically how would EPA handle reporting the following situations?
1.  A compressor is located on the well pad of well A.  This compressor is a gas lift compressor that provides gas lift to wells B and C.  This is a small compressor that is not required to be permitted and receives gas from a gathering line and is not tied to well A in anyway.  Wells B &C flow to a central tank battery different from well A.  How would this "facility" be reported in the Part 1 information request?
2.  A centralized gas lift facility with multiple compressors provides gas lift to potentially 50 wells.  These 50 wells flow to 20 different intermediate pads with the initial separation equipment on them and then to 4 different centralized tank batteries.  Do these wells need to be listed on the gas lift facility, the intermediate pad, and the individual tank batteries they flow to?  How should this "facility" be reported in Part 1 of the information request?
3.  In an area where the well head is on one pad, the production equipment (separator and heater treater) are located on an "intermediate pad", and the final separation and storage takes place at a centralized tank battery how should this be reported in the Part 1 information request given that intermediate pads don't have names and are low emission sites that often don't require permits?
4.  At a location a compressor is used to boost pressure along a pipeline. The compressor is not attached to any particular well and does not require a permit.  How would this facility be reported in Part 1 of the information request?  Would we be required to list all the wells that are on that pipeline?
EPA has added definitions of "Well surface site" and "Centralized production surface site" to the ICR and removed the definition of "Facility" from Part 1 to provide clarity.
 Assuming A, B, and C fit the definition of well surface site, then the o/o will have to report information on well surface sites A,B, and C in Part 1. The o/o will also report information on central tank battery and this will be considered a centralized production surface site. The compressor is part of Well Surface Site "A" and would be reported under well surface site A in Part 1.
 Each of the 20 intermediate pads would likely be considered a well surface site and the o/o will have to fill out Part 1 as well surface sites, and each of the 4 centralized tank batteries would be a centralized production surface site and would be reported as such in Part 1.  The centralized gas lift facility would also be considered a well surface site and these wells reported as injection wells.
 All three appear to be independent surface sites.
 If the compressor is before the point of custody transfer and on a surface site, then it needs to be reported as a surface site, if it is beyond the point of custody transfer, it would likely be considered a gathering and boosting station facility and would not be required to fill out Part 1.
-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 Part 1 of the ICR to request information from "Well Surface Sites" and "Centralized Production Surface Sites." If additional rows/columns are required, facilities should contact EPA to request a larger/additional spreadsheet.

Part 1 Definitions

-0049
"API Well ID" and "US Well ID" are listed twice, despite seemingly being the same thing. We suggest EPA combine these definitions to avoid confusion.
EPA has included only the definition of US Well ID.
-0061
ATMOSPHERIC STORAGE TANK:
 Heater treaters often refer to a separate heater designed to break emulsions, and are not always part of a tank system, so this reference should be deleted to avoid confusion.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0036, -0050, -0065, -0064
FACILITY:
 EPA should adjust the definition of facility to fit the Source Determination Rule.
 Or a different definition of facility should be used.
EPA has added definitions of "Well surface site" and "Centralized production surface site" to the ICR and removed the definition of "Facility" from Part 1 to provide clarity.

-0068
FLOWBACK:
 The proposed definition of flowback only refers to natural gas wells, but oil wells also undergo flowback and produce flowback fluids. The proposed definition should be expanded to also include oil wells.
EPA has amended the definition of "Flowback" to include oil wells.
-0050
GAS-TO-OIL RATIO:
 Recommendation: Gas-to-Oil Ratio  -  the ratio of the amount of hydrocarbon gas that is generated by the decrease in pressure or increase in temperature to standard conditions to the amount of hydrocarbon liquid that remains after the gas has been liberated.
EPA has revised the definition of gas-to-oil ratio after considering this and other comments on this definition for Part 2..
-0068
HYDRAULIC FRACTURING:
 The current proposed definition includes the phrase "pressurized fluids containing any combination of water, proppant, and any added chemical" (emphasis added), but water is not the only base fluid used in hydraulic fracturing; some operations use gas or a mixture of gas and water as the base fluid.
 The current proposed definition specifies that hydraulic fracturing is used to penetrate "tight formations," but does not define this term. Hydraulic fracturing is also used in conventional formations with higher permeability (for example, to bypass formation damage near the wellbore).
 The current proposed definition includes the phrase "subsequently require high rate, extended flowback to expel fracture fluids and solids during completions." The terms "high rate" and "extended" are vague and undefined. Additionally, not all fracturing jobs may require "high rate" or "extended" flowback, particularly lower-volume hydraulic fracturing.
 EPA should collect data on all types of fracturing, not only high-volume, high-pressure fracturing which occurs in unconventional reservoirs, and should revise the definition.
EPA has amended the definition of "Hydraulic Fracturing" to include all types of fracturing.
-0061
INJECTION WELL:
 Injection wells as utilized in the well site definition in Part 1, Table 3 should be limited to wells that store natural gas or carbon dioxide in depleted natural reservoirs.
 Recommendation: Injection Well  -  Underground Injection Control (UIC) permitted well intended to store natural gas or carbon dioxide in depleted reservoirs. It does not include wells permitted for produced water or O&G waste disposal, injection of fluids (i.e., water, steam or carbon dioxide) for the purpose of Enhanced Oil Recovery (EOR), or to inject crude oil, condensate, or LPG into salt dome for storage purposes.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
MANNED FACILITY:
 EPA should define the minimum expectation for operators to determine if a facility is "manned".
 Recommendation: Manned Facility  -  Any facility that is visited by employees for at least 40 hours per week.
EPA has moved manned facility to Part 2.
-0061
ONSHORE PETROLEUM AND NATURAL GAS PRODUCTION FACILITY:
 Since the definition requires the facility to have a well that produces crude oil and/or natural gas, then a more appropriate term for this definition would be "onshore production well facility".
 Producing wells may be co-located with other facilities such as a compressor station, central tank battery, or gas processing plant that processes crude oil and natural gas from other locations. The current definition of facility would include this equipment that is not the target of Part 1 surveys. This confusion could be eliminated by including "from wells located on that surface site and" before the phrase "located at the facility" at the end of the current definition.
EPA has deleted the word "facility" from this term and revised its definition to define the production industry segment.  We also removed the definition of "facility" from Part 1 and added definitions of "Well site facility," "Well surface site" and "Centralized production surface site" to the ICR to provide clarity for information requested in the Part 1 survey.

-0061
ONSHORE:
 EPA should clarify that platforms, production barges, or other operations not accessible by roads are not within the scope of the ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
SEPARATOR:
 Separator is a general term that typically means any vessel that separates phases (either gas from liquid or hydrocarbon liquid from aqueous liquid) by differences in density. The definition provided is much narrower and is better described by the term "production or inlet separators".
 The phrase "whose liquid portion flows directly to an atmospheric storage vessel" should be added at the end of the definition to exclude separators that do not feed liquid directly to an atmospheric storage vessel.
EPA has considered and evaluated this comment. For the purpose of this ICR, we specifically want the term separators to refer to vessels that perform gas-liquids separation. We have generalized this definition to note that the gas may be separated "from one or more liquid fluids."
-0036
SEPARATOR:
 Should exclude the term "tank"
 Recommendation: Separator  -  a cylindrical or spherical vessel used to separate oil, gas, and water from the total fluid stream produced by a well.
EPA has adjusted the definition of Separator to mean, "A process vessel specifically designed to separate gaseous fluids from one or more liquid fluids produced from a well or as received via a pipeline. Generally, separators are operated at pressures greater than ambient air pressure."
-0061
STRIPPER WELL:
 Recommendation: Stripper well  -  Any gas or oil well with total production of natural gas and hydrocarbon liquids (i.e., crude and/or condensate) of 15 barrels oil equivalent (boe) per day or lower.
EPA has adjusted the definition of Stripper well to mean, "A well that produces 15 barrels of oil equivalent (BOE) or less per day on average over a 12-month period."

WELL SHUT-IN PRESSURE:
 Recommendation: Well Shut-In Pressure  -  The surface force per unit area exerted at the top of the wellbore when the wellhead valve is closed for 12 hours.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
WELL-SITE:
 The term "injection well" should be removed from the definition of well-site, as gas injection wells are not found at production sites and more commonly are found at natural gas storage facilities.
EPA has added definitions of "Well surface site" and "Centralized production surface site" to the ICR and removed the definition of "Facility" from Part 1 to provide clarity.

-0048
The definition of "onshore petroleum and natural gas production facility" and "facility" in Part 1 needs to be removed to avoid confusion and inconsistencies in information received. EPA defines several terms that make it confusing for operators to interpret the data requested by facility in Part 1. Specifically, EPA defines "facility", "well site", and "onshore petroleum and natural gas production facility" in Part 1, but these definitions are not consistent and could lead operators to inconsistently report Part 1 data due to the conflicting definitions. We are concerned that these terms will cause confusion over which pieces of equipment are intended to be included, and where the boundary should be drawn for reporting.
EPA has deleted the word "facility" from this term and revised its definition to define the production industry segment.  We also removed the definition of "facility" from Part 1 and added definitions of "Well site facility," "Well surface site" and "Centralized production surface site" to the ICR to provide clarity for information requested in the Part 1 survey.

Part 2 Questionnaire

Instructions Tab

-0031
EPA should provide additional clarification of date period of information requested in the intro tab and each equipment tab.  Only blowdowns have been specified as 2015 data.
EPA has amended the ICR to request RY 2015 data, when applicable.
-0049
EPA clarify that only wells and equipment operated by the company are included in the company's response to EPA which will avoid duplicative reporting by both the owner and operator
EPA will allow operators to review and correct contact information prior to sending out Part 1 and Part 2 of the ICR.  Operators should visit https://oilandgasicr.rti.org/ before October 30, 2016 to make any necessary corrections.
-0061
If an asset changed ownership after December 31, 2015, then the facility should not be considered within the scope of the ICR survey. Former owners and operators should not be required to provide information about facilities no longer under their control, even if some information is retained after closing. This is consistent with the transition requirements in the GHGRP.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
EPA should provide more detailed instructions for responding to each data element of the ICR to ensure operators have a clear understanding of the data EPA is requesting on each response tab.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Shifting information from the Intro tab to the appropriate sheets would facilitate responses.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
The introduction must contain detailed information on how to make the submittal using the e-GGRT system, including user registration for those not already in the system
EPA agrees with this comment and has implemented this suggestion. e-GGRT directions will supplied with the ICR.
-0046
Edit the Questionnaire Introduction/Instruction Sheet for "Tank Separators" as follows:
This information should be completed for all atmospheric storage vessels at the facility, including produced water, condensate, or hydrocarbon storage vessels except for tanks used to store glycol (including, but not limited to, ethylene glycol, triethylene glycol and propylene glycol), antifreeze, lube oil, used oil, amine (including diethanolamine and diethylamine), methanol, corrosion inhibitors (including H2S scavenger), solvent, diesel (or generator fuel), and water treatment chemicals and other auxiliary tanks.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0064
EPA should only require Part 2 to be completed for two wells and associated production equipment regardless of the total number of wells within the contiguous property. This would be consistent with the evaluation EPA performed for the ICR. The EPA should default to the operator to select the second well (EPA will provide the API well number for the first) which will be included in the Part 2 response or the EPA should provide guidance on how to select which two wells should be included in the response.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Acronyms/Definitions Tab

-0054
The Part 2 survey includes an Acronyms worksheet, but there are a number of acronyms throughout the worksheets that are not included on that sheet or defined. EPA should thoroughly review all worksheets and list all acronyms in the Acronym worksheet.
EPA has reviewed all acronyms within Part 2 of the ICR to assure that they are defined in the Acronyms Tab.
-0064
It should not be assumed that terms such as "abandoned well" or "well pad" are consistent across the oil and gas industry or consistently understood by the various entities that regulate oil and gas facilities.
EPA is no longer using the term "well pad" and is using the term "plugged" or "plugged/abandoned" and has added a definition of "Plugged well".
-0049
"Oil Well/Oil Reservoir" and "Gas Well/Gas Reservoir" definitions in their current forms will create confusion and should instead be amended to match state or land agency definitions.
EPA has considered and evaluated the impacts of this comment. We need each respondent to use consistent definitions for these terms consistent with our GOR groupings so we are not revising these definitions.
-0027
EPA should provide clarification/distinction between production well sites and storage wellheads, particularly with respect to the "Well Site" definition and the "Well Sites" tab.  Commenter is unsure if "Well Sites" tab in applicable to storage operations.
EPA has added the Injection-Storage Wells Tab to account for storage operations.
-0064
Definitions should be provided for terms such as "manned", "field office", "general office", "well pad", "capped well", "abandoned well", "injection well", "process tank", "gathering line", "major process equipment", "leak", "dump valve", amongst others.
EPA has considered this comment and has included some additional definitions as appropriate.
-0046
The following terms do not have definitions:
 Equipment Leaks: "Gas Service," "LNG Service," "Light Crude Service," and "Heavy Crude Service" (40 CFR 60.481a, NSPS Subpart VVa has definitions for "In gas/vapor service," "In heavy liquid service," and "In light liquid service." 40 CFR 60.5430a, NSPS OOOOa has a definition for "In light liquid service." GPA Midstream is not aware of a definition for "LNG Service")
 Tanks Separators: "Floating Roof" (40 CFR 60.111, NSPS Subpart K has a definition for "Floating Roof")
 Tanks Separators: "Gasketted, lockdown thief hatch," "Ungasketted, lockdown thief hatch," "Gasketted, spring-loaded thief hatch," "Ungasketted, spring-loaded thief hatch," "Gasketted, dead-weight thief hatch," "Ungasketted, dead-weight thief hatch." GPA Midstream is not aware of where these terms are currently defined.
 Tanks Separators: "Continuous Monitor." GPA Midstream in unclear whether this is limited to a monitor that is sending real time information to a control panel and/or data recorder.
 Pneumatics: "Chemical injection piston pump," "Chemical injection diaphragm pump," "Liquid Circulation (Kimray) pump." (40 CFR 98.6 defines "Absorbent circulation pump.")
 Equipment Leaks: "Optical gas imaging," "EPA Method 21/OVA," "Any visible emissions using OGI" ("OGI" is not defined). (40 CFR 60.18(g)(4) defines "Optical gas imaging instrument." For these comments, GPA Midstream assumes "OVA" means "Organic Vapor Analyzer", not "Olfactory, Visual, Audible."
 Equipment Leaks: "Screening/Infrared laser beam illuminated," "Screening/Acoustic leak detection". GPA Midstream is not aware of where these terms are currently defined (these terms are used in the GHGRP but not defined).
 Equipment Leaks: "In-line heater." GPA Midstream is not aware of where this term is currently defined.
 Compressors: "Calibrated bagging," "High volume sampler." (40 CFR 98.6 defines "Calibrated bag.")
 Compressors: "Liquefied Petroleum Gas (LPG)." GPA Midstream is not aware of where this term is currently defined.
EPA has considered this comment and has included some additional definitions as appropriate.
-0061
ARTIFICIAL LIFT: Although the proposed definition comes from the final NSPS OOOOa, it was not proposed and is not utilized in the regulation.
 Recommendation: Artificial lift - A wellbore deliquification technique which utilizes added energy, which includes surface compression, sucker rod pumps, progressive cavity pumps, electric submersible pumps, jet pumps, and gas lift.
EPA has adjusted the definition of Artificial lift to mean, "A wellbore deliquification technique that adds energy to the fluid column in a wellbore. Artificial-lift systems use a range of operating principles and include surface compression, sucker rod pumps, progressive cavity pumps, electric submersible pumps, jet pumps, and gas lift."
-0061
ASSOCIATED GAS: Currently, EPA's definition of associated gas would include any natural gas from a well that also produces liquid hydrocarbons. This definition can be corrected by deleting the phrase "that also produce hydrocarbon liquids" and replacing it with "at oil wells".
EPA agrees and has adjusted the definition of Associated gas to mean, "The natural gas which originates at oil wells and occurs either in a discrete gaseous phase at the wellhead or is released from the liquid hydrocarbon phase by separation."
-0061
ATMOSPHERIC STORAGE TANK: This definition from the Part 1 survey should be added to the Part 2 survey definitions.
EPA agrees and has added the definition of Atmospheric storage tank to mean, "A class of storage tanks that store materials at approximately atmospheric pressure.  Atmospheric storage tanks may store liquids at ambient temperatures or at elevated temperatures (e.g., "heater treaters")."
-0054, -0046, -0061
BLOWDOWN:
 The definition of blowdowns should be consistent with the GHGRP.
 Certain blowdown events shouldn't be considered as blowdowns.

We have revised our definition to make it clear that maintenance releases are considered to be blowdowns. The adjusted definition of Blowdowns is: "The act of releasing gas from a well, process unit, or pipeline to reduce the pressure of the system or to prepare equipment for maintenance or cleaning, such as pigging."
-0061
CENTRIFUGAL COMPRESSORS: The definition should specifically exclude vapor recovery compressors.
Vapor recovery compressor is a compressor. EPA has added the data field, "Operational Service" to include Transportation, Vapor Recovery, Refrigeration, and Other.
-0064
The definition of "centrifugal compressor" should be limited to units compressing natural gas. In addition, the definition should only apply to compressors which operate using centrifugal action.
We have added other compressor types including wet seal, screw, and scroll compressors to the, "Compressor Type" picklist.
-0046
COMPONENTS (OR EQUIPMENT COMPONENTS):
 Since all the component types are listed in the Equipment Leaks sheet of the questionnaire, this definition should either be eliminated or copied from an existing regulation such as NSPS Subpart KKK or OOOO.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
COMPRESSOR STATION:
 The proposed ICR definition is identical to NSPS Subpart OOOO. This definition should clearly delineate the sector boundary and what equipment/sources are to be included and excluded.
The term "Compressor station" is a general term that is used in the various industry segment definitions, so we have retained the general NSPS OOOO definition and we have refined the industry segment definitions to clarify what equipment is included at a facility within each industry segment. From these definitions, it is clear that the presence of compressors at a facility does not make that facility a gathering and boosting or a transmission compression "compressor station" facility.
-0054
COMPRESSOR:
 From 40 CFR 98 subpart W, section 98.238: Compressor source means the source of certain venting or leaking emissions from a centrifugal or reciprocating compressor. For centrifugal compressors, "source" refers to blowdown valve leakage through the blowdown vent, unit isolation valve leakage through an open blowdown vent without blind flanges, and wet seal oil degassing vents. For reciprocating compressors, "source" refers to blowdown valve leakage through the blowdown vent, unit isolation valve leakage through an open blowdown vent without blind flanges, and rod packing emissions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
CONDENSATE:
 Definition is identical to NSPS subpart OOOO. Subpart W definition is preferred.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061, -0054, -0046
CONTINUOUS BLEED PNEUMATIC CONTROLLER:
 The definition should be adjusted to match Subpart W.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
CONTROL DEVICE:
 Recommendation: Control Device - For the purpose of this ICR, control device is limited to equipment that is utilized to recover or reduce emissions from a hydrocarbon process stream. A control device includes, but is not limited to, traditional candlestick flares, enclosed flares, thermal oxidizers/incinerators, vapor recovery units and carbon adsorption systems. Engine catalysts are not included for this request.
EPA has added a general definition for "Control device" and also a definition of "Organic emissions control device" the latter being similar to the suggested definition. We also revised the instructions in the control device tab to be specific to organic emissions control devices.
-0049
The definition of "Crude Oil" includes the term "drip gases." EPA should clarify whether drip gas is a reference to condensate. If so, it should be removed from the crude oil definition, as condensate is defined separately.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
CUSTODY TRANSFER:
 The proposed ICR definition is identical to NSPS Subpart OOOO and is acceptable.
 NSPS Subpart OOOOa definition is different (refers to oil as well as natural gas).
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
CUSTODY TRANSFER:
 This term does not appear to be used in the questionnaire sheet and should be removed.
Custody transfer is used in the new definition of "Gathering and boosting compressor station facility" so EPA has retained this definition.
-0068
DIRECTIONAL WELL:
 Remove.  See "Horizontal Well."
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
FACILITY:
 GHGRP section 98.6 "facility" definition is preferred.
 The final ICR should more clearly define "facility" for transmission pipelines, and Subpart W definition is available.
EPA has revised the definition of facility for the purposes of this ICR and have added a number of other definitions such as "Well surface site," "Well Site Facility," and "Centralized production surface site" and "Gathering and boosting compressor station facility" to help clarify the definition of "Facility" for the purposes of responding to Part 2 of this ICR.

-0046, 59
FACILITY:
 Definition should match the most recent "Source Determination Rule" for oil and gas facilities release on June 3, 2016.
The revised definition of facility incorporates special definitions for production, gathering and boosting, and transmission pipeline facilities. We consider these special definitions of facility to be more useful for supporting standards development for existing sources. For other industry segments, the definition of facility is consistent with the source determination rule..
-0049
The current definition of "Facility" is unclear and could be a source of confusion for locations that have physically co-located but functionally unrelated equipment, or locations that with functionally related equipment located off-site. For instance, if an operator has a compressor for boosting pipeline pressure and a tank battery on the same location that does not sell to the pipeline, it is unclear if EPA would consider this one or two distinct locations
We have revised the definition of facility, which now incorporates special definitions for production, gathering and boosting, and transmission pipeline facilities to provide clarity. In any event, all equipment (or pollutant-emitting activities) co-located at a single surface site under common control is considered to be one facility, regardless of "functionality."
-0046
FIELD QUALITY NATURAL GAS:
 EPA should evaluate this definition to determine whether it will provide the agency the information it seeks, since the term itself does not provide any information about gas composition.
 Field gas may be of an acceptable composition and heating value (btu/scf) to be sent from the wellhead to transmission pipelines without any processing. Field quality natural gas can be rich or lean.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
GAS-TO-OIL RATIO:
 It is unclear if "Gas-to-Oil Ratio" (GOR) is the same GOR that an operator would obtain from a flash analysis after a separator.
 EPA should clarify this definition to "the ratio of the amount of hydrocarbon gas that is generated by the decrease in pressure or increase in temperature to standard conditions to the amount of hydrocarbon liquid that remains after the gas has been liberated" which more accurately describes the necessary change in pressure and temperature.
The definition of Gas-to-oil ratio has been adjusted to mean, "The ratio of the volume of natural gas that is produced or that comes out of solution when crude oil is extracted from a well equilibrated to standard conditions to the volume of hydrocarbon liquids (oil and condensate) produced after the natural gas comes out of solution. This is often calculated by dividing the measured natural gas production by the measured crude oil and condensate production."
-0061
GAS-TO-OIL RATIO (GOR) AND GAS LIQUID RATIO (GLR):
 The GOR definition proposed for Part 2 is in conflict with the GOR definition in Part 1, the oil and gas industry's understanding of GOR, and application of GOR for use in the Well Site, Table 2 General Well Information.
The definition of Gas-to-oil ratio has been adjusted to mean, "The ratio of the volume of natural gas that is produced or that comes out of solution when crude oil is extracted from a well equilibrated to standard conditions to the volume of hydrocarbon liquids (oil and condensate) produced after the natural gas comes out of solution. This is often calculated by dividing the measured natural gas production by the measured crude oil and condensate production."
-0049
HEATER TREATER:
 "Heater Treater" definition should be changed to read "Process Vessel" instead of "Storage Vessel" as heater treaters are not storage vessels.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0064
HEATER TREATER:
 In California, a "heater treater" is a vessel that operates well above atmospheric pressure. The example of a "heater treater" is not consistent with the stated definition of "atmospheric storage tank".
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
HORIZONTAL WELL:
 Revise title to "Directional/ Horizontal well"
 Recommendation: Directional/ Horizontal well - Wells where a section of the wellbore intentionally deviates from the vertical, allowing access to oil and gas reserves located at points different from directly beneath the wellhead.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
HYDRAULIC FRACTURING:
 Recommendation: Hydraulic fracturing - The process of directing pressurized fluids containing any combination of water, proppant, and any added chemicals into subsurface geological formations to improve or restore permeability.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action. Note, in response to another comment, we did generalize the definition of hydraulic fracturing to all types of formations (not just tight gas formations).
-0061
INJECTION WELL:
 Recommendation: Injection Well  -  "Underground Injection Control (UIC) permitted well intended to store natural gas or carbon dioxide in depleted reservoirs. It does include wells permitted for produced water or O&G waste disposal, injection of fluids (i.e., water, steam or carbon dioxide) for the purpose of Enhanced Oil Recovery (EOR), or to inject crude oil or LPG into salt dome for storage purposes."
EPA has added an "Injection-Storage Wells" tab and associated definitions. EPA does not intend to limit injection wells to just natural gas.
-0054
INTERMITTENT BLEED CONTROLLER:
 Pneumatic controller definitions should be consistent with the pneumatic categories in Subpart W and Subpart OOOO; eliminate all of the additional categories of pneumatic devices in the Proposed ICR.
 The additional data is not readily available.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
INTERMITTENT BLEED CONTROLLER:
 Recommendation: Intermittent Vent Controller - A pneumatic controller that has a mechanical barrier between the supply gas and the end device. These units do not allow supply gas and a vent port to be open at the same time.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
INTERMITTENT VENT CONTROLLER:
 Recommendation: Intermittent Vent Controller - A pneumatic controller or solenoid valve that has a mechanical barrier between the supply gas and the end device. These units do not allow supply gas and a vent port to be open at the same time and do not have a continuous bleed.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
ISOLATION VALVE:
 Isolation valve term is included in Subpart W, section 98.238 definition of compressor source but it is not defined. If this definition is retained in the final ICR, INGAA suggests deleting "usually for maintenance or safety purposes."
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
LIQUIDS UNLOADING:
 Artificial lift should be excluded from the definition. No emissions occur from these operations.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
MANNED FACILITY:
 Recommendation: Manned Facility  -  Any facility that is visited by employees for at least 40 hours a week.
A drop down picklist has been added of how often the site is visited.
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MAXIMUM AVERAGE DAILY THROUGHPUT:
 EPA should remove this term and not use this concept in the ICR, because the throughput during the 30-day potential-to-emit evaluation period may be irrelevant to current throughput.
 This term and concept were only recently introduced with NSPS OOOO, so for existing tanks, this data will not be available.
 The forms generally contain terms like "average flow rate" or "average throughput." These terms are acceptable, with the caveat that EPA should define calendar year 2016 as the period/averaging period for all data to ensure a consistent reporting basis across operators.
 EPA appreciates the comment and will implement as suggested and has removed this definition.
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NATURAL GAS (NG):
 GPA Midstream notes that EPA does not define "pipeline quality" and may want to do so, depending on the application of this definition.
 Assumed this term is used to refer to gas that meets transmission and distribution sector quality specifications. The processed gas stream from a gas plant (residue gas) meets these kinds of specifications, and field gas in some areas of the county may also meet these specifications.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
NATURAL GAS LIQUIDS:
 This definition is not adequate as it does not refer to the liquid state of these hydrocarbons, it uses an undefined term "extracted," and it uses the term "field quality" which seems to be an unnecessary qualifier for "natural gas."
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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NATURAL GAS TRANSMISSION PIPELINE FACILITY:
 There is an associated definition in Subpart W for pipeline operator rather than "facility," which includes similar text to the proposed ICR definition (see next item below).
 The final ICR definition needs to more clearly delineate the difference between "pipeline" facilities and "compressor station" facilities to ensure boundaries are defined and consistent responses are ensured. Additional text should be included in final ICR definitions or in final ICR support documents.
 There is an associated definition in Subpart W containing owner or operator but it does not define "facility."
 See comment above regarding the need for clear delineation of segments  -  i.e., "natural gas transmission pipeline" facilities and "natural gas transmission compressor station" facilities.
 There is an associated definition in NSPS Subpart OOOO but it does not define "facility."
We have defined "Transmission Pipeline Facility" to be: "For the purposes of this ICR, all onshore transmission pipelines within a given state that is under the control of the same person (or persons under common control)."
-0046
NET HEATING VALUE:
 Industry standard practice is to measure/use gross heating value (also known as, Higher Heating Value or "HHV")
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
ONSHORE NATURAL GAS PROCESSING PLANT (FACILITY):
 This definition from NSPS, Subpart OOOO (and previously Subpart KKK) has been clarified in Applicability Determinations (AP) to mean "forced extraction", thus eliminating gravity separation of liquids from the interstage coolers on compressor skids.
EPA has adjusted the definition of Onshore natural gas processing to mean, "The oil and gas industry segment that is engaged in the extraction of natural gas liquids from field quality natural gas, fractionation of mixed natural gas liquids to natural gas products, or both at an onshore facility.  A Joule-Thompson valve, a dew point depression valve, or an isolated or standalone Joule-Thompson skid is not an onshore natural gas processing facility."
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ONSHORE NATURAL GAS PROCESSING PLANT (OR FACILITY):
 To avoid any confusion with facilities that have gravity separation of liquids, GPA Midstream suggests that EPA revise the definition as follows, along with the definition of "forced extraction of natural gas liquids" proposed above.
EPA has adjusted the definition of Onshore natural gas processing to mean, "The oil and gas industry segment that is engaged in the extraction of natural gas liquids from field quality natural gas, fractionation of mixed natural gas liquids to natural gas products, or both at an onshore facility.  A Joule-Thompson valve, a dew point depression valve, or an isolated or standalone Joule-Thompson skid is not an onshore natural gas processing facility."
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ONSHORE NATURAL GAS TRANSMISSION COMPRESSOR STATION:
 There is an associated definition in Subpart W but it does not define "station."
 See comments above on clear delineation of transmission facilities.
EPA has adjusted the definition of Onshore natural gas transmission compression to mean, "The oil and gas industry segment whose primary function is to move natural gas from production facilities, gathering and boosting facilities, natural gas processing plants, or other transmission compressor stations through transmission pipelines to natural gas distribution pipelines, LNG storage facilities, or into underground storage using a combination of onshore compressors. Facilities in this industry segment are referred to as Onshore natural gas transmission compressor stations and these facilities may include equipment for liquids separation, and tanks for the storage of water and hydrocarbon liquids; however; the Onshore natural gas transmission compression industry segment does not include facilities that have compressors but that are in the production, gathering and boosting, or processing industry segments."
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ONSHORE PETROLEUM AND NATURAL GAS GATHERING AND BOOSTING FACILITY:
 There is an associated definition in Subpart W that is preferred.
EPA has revised this series of definitions to define the industry segment. The adjusted the definition of Onshore petroleum and natural gas gathering and boosting to mean, "The oil and gas industry segment that uses onshore gathering pipelines and other equipment to collect petroleum and/or natural gas from onshore petroleum and natural gas production facilities and to compress, dehydrate, sweeten, or transport the crude oil , condensate and/or natural gas to a natural gas processing facility, a transmission pipeline or to a natural gas distribution pipeline.  See also Gathering and boosting compressor station facility."
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ONSHORE PETROLEUM AND NATURAL GAS GATHERING AND BOOSTING FACILITY:
 Mixing definitions for petroleum facilities with natural gas facilities simply does not make sense and does not have reasonable application.
 Industry does not think of the "gathering and boosting" industry segment as an industry segment that moves petroleum; rather it is a natural gas business.
 Respectfully requests that EPA not propagate this definition from the GHGRP into this ICR process or into any future rulemaking for the gathering and boosting industry segment.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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PNEUMATIC CONTROLLER:
 Recommendation: Pneumatic Controller  -  An automated pneumatic device that responds to a process variable by altering a gas pressure signal to an end device.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0050
PNEUMATIC CONTROLLERS  -
 Recommendation: Pneumatic Controllers  -  Any device which generates or is powered by compressed air or natural gas and has the potential to emit natural gas which includes pneumatic controllers.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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PNEUMATIC DEVICE:
 Air driven pneumatics devices are not regulated equipment. Eliminate this separate definition for pneumatic device or ensure consistency with more specific terms/definitions of continuous bleed, intermittent bleed, zero bleed, no bleed pneumatics and pneumatic controllers. If this definition is retained in the final ICR, delete the word "pneumatic" prior to valve actuators and pumps.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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PNEUMATIC DEVICE:
 The phrase, "which generates or" should not be used, as this would seem to include the air/gas compression system in with the users of the pneumatic power.
 Concerned that EPA could adopt a very loose or overly broad interpretation of "pneumatic device" to include any equipment that generates natural gas emissions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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PNEUMATIC DRIVEN, MOTORIZED ACTUATOR:
 Recommendation: Pneumatic Driven, Motorized Actuator  -  A turbine operated actuator, rotary vane actuator, or other pneumatic motor driven actuator driven by natural gas that opens or closes a gate type isolation valve, typically found in the transmission pipeline sector.
This term is not used in the ICR.  EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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PRESSURE VESSELS:
 "Pressure Vessels" should be defined as any vessel that operates under pressure and not atmospheric pressure, rather than the currently stated 30 psig threshold which appears to be an arbitrary distinction that would create confusion.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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RECIPROCATING COMPRESSOR:
 Maintain consistency with the definitions of "Compressor" and "Centrifugal compressor" in the proposed ICR and to align with the definition for reciprocating compressor found in the GHGRP, Subpart W
 Recommendation: Reciprocating compressor - A piece of equipment that significantly increases the pressure of a gaseous stream by positive displacement, employing linear movement of the driveshaft.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0064
The definition of "reciprocating compressor" should be limited to units compressing natural gas.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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ROTARY VANE ACTUATOR:
 New definition that should be deleted. Rotary vane actuators should be covered in a broader category that is reported consistent with the GHGRP. Terms and definitions are introduced that are inconsistent with existing nomenclature and pneumatic source categorization.
 If retained, remove the term "vane" and focus on defining a hydraulic gas actuated generic "Rotary Actuator."
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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SEPARATOR:
 Separators are absolutely not tanks.
 Recommendation: Separator - A process vessel specifically designed to separate gaseous fluids from liquid fluids produced from a well or as received via a pipeline. Generally, separators are operated at pressures greater than ambient air pressure.
We have replace the word "tank" with the word "vessel" in the definition of separator.
-0061
SEPARATOR:
 This term and definition is very general and would lead to gathering information on separators that lead to other pressure vessels, thus is not pertinent to emissions.
 Recommendation: Separator  -  A process tank specifically designed to separate gaseous fluids from liquid fluids produced from a well, received via pipeline, or other streams at a gas processing plant. For the purposes of this ICR, the liquid portion flows directly to an atmospheric storage vessel.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0064
The term separator is defined as a "process tank", but there is no definition for "process tank". Further, by including the wording "specifically designed to separate gaseous fluids from liquid fluids" in the definition of "separator", the EPA seems to be limiting this data field to two-phase separators (i.e. separates gases from liquids). Three-phase separators (i.e. separates gases, produced water and crude oil) would be excluded as they are specifically designed to separate crude oil from produced water and any offgassed vapors that can be collected.
We have replace the word "tank" with the word "vessel" in the definition of separator. We have also clarified in the definition that they are used to "separate gaseous fluids from one or more liquid fluids" so as to explicitly include "three-phase" separators.
-0049
"Separator" should clarify whether it includes gunbarrel tanks since their primary purpose is to separate water from oil and not gas from liquids.
For the purposes of this ICR, the term separator is specific to gas-liquid separators. EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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SNAP ACTING CONTROLLER:
 Newly added pneumatic category and definition. Terms and definitions are introduced that may be inconsistent with existing nomenclature and pneumatic source categorization. Snap acting controllers should be covered in a broader category that is already reported consistent with the GHGRP.
 The proposed definition is erroneous because "snap acting" refers to the controller service not the bleed/vent type, and continuous bleed controllers can be used for snap acting service.
EPA has revised the definition of snap acting controller to be:  "A controller that acts as an on/off switch and is either fully open or fully closed.  Most snap acting controllers, when functioning properly, do not have a continuous gas bleed and vent gas only when actuating and are, therefore, typically designed as intermittent bleed pneumatic devices." We have also added snap acting continuous bleed device to the list of pneumatic devices for which counts are required.
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SNAP ACTING CONTROLLER:
 Classification of intermittent vent controllers into throttling or snap-acting should be removed.
 Depending on the operational design, intermittent vent and continuous bleed controller types can be either in on/off service or throttling service.
EPA has revised the definition of snap acting controller to be:  "A controller that acts as an on/off switch and is either fully open or fully closed.  Most snap acting controllers, when functioning properly, do not have a continuous gas bleed and vent gas only when actuating and are, therefore, typically designed as intermittent bleed pneumatic devices." We have also added snap acting continuous bleed device to the list of pneumatic devices for which counts are required.
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STORAGE TANK OR VESSEL:
 Although not defined in section 98.238, Subpart W section 98.233 (Calculating GHG emissions) contains important description, explanation and distinctions for this unique source.
 The Subpart W section describes the tanks of interest for reporting flashing emissions, but these sections do not apply to T&S tanks.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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STORAGE TANK OR VESSEL:
 The exclusion in the NSPS of "process vessels such as surge control vessels, bottoms receivers or knockout vessels" is not included in this ICR definition.  This exclusion must be included, as process vessels are present at existing oil and gas operations but do not have emissions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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STORAGE TANK OR VESSELS:
 The Part 2 definition differs from the Part 1 definition.  See above comment.
The definitions for Storage tank or vessel has been made consistent in Part 1 and 2.
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THROTTLING CONTROLLER:
 Recommendation: Throttling controller - A controller that can provide a variable signal based on the deviation from the desired set point. A throttling controller is designed to hold an end device in an intermediate position and move it from any position to more or less open without a requirement to go fully open or fully shut every actuation cycle.
EPA accepts this definition and has added it to the spreadsheet.
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THROTTLING CONTROLLER:
 New definition. The Proposed ICR introduces terms and definitions that are inconsistent with existing nomenclature and pneumatic source categorization. Throttling controllers should be covered in a broader category that is reported consistent with the GHGRP.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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THROTTLING CONTROLLER:
 EPA's proposed definition of throttling controller does not correctly define throttling service and can apply to both a throttling controller and an on/off controller that does not fully actuate. EPA's proposed definition of throttling controllers confuses the effort of identifying controllers operating in that service.
 Recommendation: Throttling controller - A controller that is designed to hold an end device in an intermediate position and move it from any position to more (or less) open without a requirement to go to fully open or fully shut every actuation cycle.
EPA wants to collect more detailed information on pneumatic devices. We have revised the definition of throttling controller to conform with the recommended definition provided here and a similar comment.
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TOTAL COMPRESSOR POWER RATING:
 New definition. Reciprocating engine and turbine NSPS and NESHAPs include definitions for comparison and consistency. Those definitions rely on ISO rated hp for turbines & nameplate hp or site rated hp for reciprocating engines.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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TOTAL COMPRESSOR POWER RATING:
 Definition mixes information about the compressor and the compressor driver (which are nearly always separate and distinct pieces of equipment).
 Recommendation: Total compressor driver power rating - The nameplate brake horsepower of the compressor driver.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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TURBINE OPERATED ACTUATOR:
 New definition contains a typo. The Proposed ICR introduces terms and definitions that are inconsistent with existing nomenclature and pneumatic source categorization. Turbine operated actuators should be covered in a broader category that is reported consistent with the GHGRP.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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UNDERGROUND STORAGE VESSEL:
 EPA should modify this definition to align with concepts used in SPCC (see 40 C.F.R. § 112.2) and RCRA (see 40 C.F.R. § 280.12).
 GPA Midstream cannot offer a specific definition for this term because it is unknown how EPA intends to use it.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
VERTICAL WELL:
 Recommendation: A well that is intentionally deviated from the vertical, allowing access to oil and gas reserves located directly beneath the wellhead.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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VOLATILE ORGANIC COMPOUNDS (VOC):
 There is a typo at the end of this definition, "Compounds that have been determined to have negligible photochemical reactivity, such as methane and ethane, are excluded from the define" [sic].
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
WELL DEPTH:
 Revise title to "True Vertical Depth"
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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WELL HEAD (OR WELLHEAD):
 Distinction between production and storage wellhead desired. This definition should exclude storage wellheads.
 Storage wellhead component counts are available in e-GGRT.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
WELL SITE:
 Match Part 1 definition.
EPA has changed this to "Well Site Facility" and is now consistent between Part 1 and Part 2.
-0064
The definition of well site includes the term "facilities". A "facility" is defined as contiguous or adjacent properties. Further explanation is needed as to how a well site can incorporate numerous facilities.
EPA has revised the definition of facility for the purposes of this ICR and have added a number of other definitions such as "Well surface site," "Well Site Facility," and "Centralized production surface site" and "Gathering and boosting compressor station facility" to help clarify the definition of "Facility" for the purposes of responding to Part 2 of this ICR.
-0061
WELL TESTING: Match Subpart W definition.
The definition of Well testing has been added to mean "The determination of the production rate of a well or an assessment of reservoir characteristics for regulatory, commercial, or technical purposes. Well testing may or may not require venting of gas at the well surface site."
-0068
WELLBORE LENGTH:
 Revise title to "Measured Depth"
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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ZERO BLEED PNEUMATIC CONTROLLER:
 New definition that is not complete in the Proposed ICR or other regulations. If this term is retained in the final ICR definitions, the definition should differentiate between no bleed, low bleed, and devices that may use solar, electric, or instrument air. This definition should also address pneumatic devices equipped with a gas capture system.
 Related definition in NSPS Subpart OOOOa provides for pneumatics driven by a gas other than natural gas, with no natural gas emissions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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ZERO BLEED PNEUMATIC CONTROLLER:
 EPA should delete this term from the ICR.
 The definition proposed in the ICR has two conflicting statements and ultimately lead the user to determine the device is an intermittent vent device, which EPA has already established as a sub category.
 If the device does not release gas to the atmosphere there is no value in the information reported and could not reliably be used to determine overall impacts.
 The term zero bleed pneumatic controller is a marketing term with no discernible meaning.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
ZERO BLEED PNEUMATIC CONTROLLER:
 This term should be removed from the definitions.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Facility Tab

Table 1: Parent Company General Information

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Sub-Section 1. Parent Company General Information Recommend that individual responders be allowed to decide the appropriate Legal Name to use for each facility. What is often thought of as one "company" often consists of a large family of affiliated corporations, limited liability corporations, and partnerships.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Sub-Section 1. Parent Company General Information EPA should define or explain the term "Parent Company" in this request, especially as compared to the GHGRP.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054, 48
Row 3 Column A - Number of Employees:
 The number of employees of the parent company is not pertinent to the identification of the types and prevalence of emission controls or emission reduction measures and potential costs for the measures and controls. Remove question.
 If field is retained, provide drop down with bracketed counts. Since this is for parent company, recommended drop down is [ <100 ] [ 101-5,000 ] [ >5,000 ]
 EPA could more easily address this question by providing the necessary definition of a small business in the oil and natural gas production industry and have a pull down "yes" or "no" response.
EPA has added the elements of the definition of "Small Business" to the definitions tab and has amended Table 1 to request "Does this company meet the definition of small business?"
-0046
Sub-Section 1. Parent Company General Information The number of employees is unnecessary information and can be misleading. Depending on the legal name and entity, this number could vary significantly due to the fact that employees may work under one corporate entity but the site is owned by another.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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Row 4 Column A - Dun and Bradstreet Number:
 The purpose of a Dun and Bradstreet Number (DUN) is to establish a business credit file and is not pertinent to the identification of the types and prevalence of emission controls or emission reduction measures and potential costs for the measures and controls. Moreover the DUN information is sometimes inaccurate and it is difficult to get Dun and Bradstreet to correct the information. This could put the operator in the unfortunate position of having to report inaccurate information to EPA. Remove question.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Sub-Section 1. Parent Company General Information Not all corporate entities will have a Dun and Bradstreet number assigned. That option should be factored in.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
Sub-Section 1. Parent Company General Information There is no reason for EPA to request the physical address for the parent company. The mailing address should be adequate.
EPA has removed requests for parent company physical address from Table 1.

Table 2: Facility General Information

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Row 25 Column B - Facility Type:
 It is possible to have a natural gas transmission compressor station and an underground natural gas storage facility operating at the same facility. The pull down only permits the selection of one type.
 Clarify which option to select if operations are in more than one segment. Definitions should clearly delineate what should be reported for each facility where multiple segments may be owned or operated by an ICR respondent.
 The Facility Types are modeled after GHGRP Subpart W industry segments. However, related definitions from Subpart W are not consistently used for ICR.
 In addition to consistency with GHGRP segment names in pull-down menu, consistent definitions are needed for segments / facilities. Not doing so creates an additional burden associated with gathering information using new (or unclear) categories.
EPA has amended Table 2 "Facility Type" to include "Onshore natural gas transmission compressor station and underground natural gas storage facility."

Operators should refer to the Definitions Tab to determine each facility's "Facility Type."

EPA has amended "Facility Type" to include "Other" and will allow operators to specify.
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`Facility Type': The categories for random sampling were selected by EPA so that the emissions from different sampling populations would be similar, and could be used to estimate the emissions for the entire population. Since EPA cannot be sure that the Surveys sent to specific operators are correctly classified for each industry segment, EPA should expect that some responses will not align with the industry category that was assigned based on the `ICR ID' used for sample selection. For example, EPA may send a survey to an operator for gas processing, but the facility may actually be a gathering and boosting compressor station.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
`Facility Type Sub-Category': Some facilities have unique operations that will not be representative of other operations of a similar `Facility Type'. There should be an optional comment field that will allow operators to provide information for these operations, if applicable to the facility.
EPA has amended "Facility Type" to include "Other" and will allow operators to specify.
-0031
If the facility type `pipeline' is indicated in cell B25, black out non-relevant facility information for pipelines (Section 2, rows 27-34, 48, 49) in the Facility tab spreadsheet.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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Facility Type is currently a dropdown selection that only allows for one option. This should be a multiple choice selection. Some facilities fall into multiple industry segments.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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"Are greenhouse gas (GHG) emissions from this facility reported under 40 CFR part 98 subpart W?"
 Facilities reporting under 40 CFR part 98 Subpart W may vary year to year based on several factors. Change the question to ask if the facility reported emissions during the previous calendar year (i.e. 2015 calendar year).
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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Row 27 Column B - Facility GHGRP ID, if applicable:
 Answering "yes" to question in row 26 should activate this field.
 This data field should be linked to the question in row 26. It should be pre-populated from e-GGRT and/or corrected to allow an entry.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046
"Facility GHGRP ID, if applicable"
 This field remains blacked out even if "Yes" is selected for "Are greenhouse gas (GHG) emissions from this facility reported under 40 CFR part 98 subpart W."
EPA has amended Table 2 to allow operators to specify a Facility GHGRP ID if applicable.
-0046
"Physical Address"
 Add "if assigned" due to the fact that a lot of sites don't have, or are not required to have, physical addresses.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
Manned Sites: The pick list options for `Is this facility manned while in operation?' should be updated to reflect if the site is consistently manned (24 hours a day, 7 days a week) or manned for a shorter time period such as during weekly daytime hours. This will more accurately reflect different operations across the various industry segments.
EPA has amended "Is this facility manned?" to include more timing options.
-0027, 54

Classify "Is Facility Manned?" as CBI.

See the Comments Response Memo for answers to CBI questions.
-0046
"Is this facility manned while in operation?"
 It is not clear whether a `manned facility' requires employees to be onsite 24 hours/day, 7 days/week, or some other time frame. Alter the question to ask if operational staff are on-site 24 hours per day. EPA could also include a dropdown with different options (i.e. 24/7 or normal business hours).
EPA has amended "Is this facility manned?" to include more timing options.
-0054, 61, 46
Include more detailed information on electrification
EPA has amended "Does the facility have electricity available?" to include a picklist of options.
-0054, 59, 46
Row 50 Column A - Year the facility first began operations can be difficult to find
EPA has removed "Year the facility first began operations" from the Facility Tab.
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Row 51 Column A - Number of months the facility operated in 2015
 The number of months the facility operated in 2015 is not pertinent to the identification of the types and prevalence of emission controls or emission reduction measures and potential costs for the measures and controls. Emissions can occur in "operating" mode or in "standby, not operating" mode. Remove question.
 The question as stated will require respondents to make subjective judgments so the responses EPA receives will not be based on consistent assumptions. For example, a compressor at a station can be on stand-by (not compressing gas) due to pipeline conditions and demand. In another scenario, other parts of the facility such as pig launcher/receiver may operate while the compressors are on stand-by or shutdown.
 There are many modes (e.g., not operating and depressurized) and interpretations of "operated."
 What if a facility operated for only a few hours or days in a calendar month?
 If field is retained, clarify terms within the question (see additional notes that follow). For example, regarding equipment leak emissions, if the facility includes pressurized equipment (e.g., compressors, piping), then the facility would be "operational." Revise header to: Number of months the facility was ready for/capable of operation in 2015. Clarify and define "operated." Clarify and define "month."
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0046, 49
"Quantity of natural gas received by the facility in the 2015 calendar year (thousand standard cubic feet). For production facilities, this is the quantity extracted from all wells. For storage facilities, this is the quantity place into storage."
 GPA Midstream recommends that the word "Estimated" be added beforehand because not all compressor stations have inlet meters.
 This is reported in the GHGRP for processing facilities per 98.236(aa)(3)(i) and for storage facilities per 98.236(aa)(5)(i). This is a redundant information request and should be removed from the ICR for processing facilities that report under the GHGRP.
 Associated gas that is not sold is most likely directed to a control device from multiple points in the separation process. Operators do not meter gas directed to a control device because it is technically infeasible.
 Operators will often use a gas to oil ratio (GOR) value to calculate total gas production. Because GOR values change over time as oil production declines, EPA should not take associated gas production data as absolute and make unjustified assumptions.
Companies should provide best available data based on existing records when responding to the ICR.
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"Quantity of natural gas leaving the facility (sales) in the 2015 calendar year (thousand standard cubic feet)."
 This is reported in the GHGRP for processing facilities per 98.236(aa)(3)(ii) and for storage facilities per 98.236(aa)(5)(ii). This is a redundant information request and should be removed from the ICR for processing facilities and underground storage facilities that report under the GHGRP.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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Gas Volumes: Depending on the industry segment, both the quantity of gas received and leaving facility are not useful parameters for emissions purposes. Only one of these values should be required to establish the relative size of facility.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
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Row 54 Column B - Quantity of all hydrocarbon liquids (crude oil and condensate, including NGLs) received by the facility in the 2015 calendar year (barrels). For production facilities, this is the quantity extracted from all wells.
 Not applicable to Transmission and Storage. Black out for T&S.
EPA has amended Table 2 to black out information requested for quantity of hydrocarbon liquids.
-0046
"Quantity of all hydrocarbon liquids (crude oil and condensate, including NGLs) received by the facility in the 2015 calendar year (barrels). For production facilities, this is the quantity extracted from all wells."
 This is reported in the GHGRP for processing facilities per 98.236(aa)(3)(iii). This is a redundant information request and should be removed from the ICR for processing facilities that report under the GHGRP.
 Natural gas gathering and boosting facilities typically do not measure liquids received at a facility; they only measure liquids exiting the facility. Because of this, operators will only be able to report the quantity of liquids leaving the facility as an estimate for the quantity of liquids received by the facility. This data element should be removed from the ICR for all gathering and boosting facilities. At the very least, EPA should add another statement defining the requirement for non-production sites.
Companies should provide best available data based on existing records when responding to the ICR.
-0054
Row 55 Column B - Quantity of all hydrocarbon liquids (crude oil and condensate, including NGLs) leaving the facility (sales) in the 2015 calendar year (barrels).
 Not applicable to Transmission and Storage. Black out for T&S.
EPA has amended Table 2 to black out information requested for quantity of hydrocarbon liquids for T&S.
-0046
"Quantity of all hydrocarbon liquids (crude oil and condensate, including NGLs) leaving the facility (sales) in the 2015 calendar year (barrels)."
 This is reported in the GHGRP for processing facilities per 98.236(aa)(3)(iv). This is a redundant information request and should be removed from the ICR for processing facilities that report under the GHGRP.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0054
Row 56 Column B - Miles of natural gas transmission pipeline
 Applicable to Pipelines only, not applicable to Transmission and Storage facilities. Cannot assign pipeline miles to individual facilities. For pipelines, the "facility" boundary should be clearly identified. Without clarification, respondents will likely have different interpretations and data quality may be impacted.
 Black out for T&S.
EPA has amended Table 2 to request "Miles of natural gas transmission pipeline" from Natural Gas Transmission Pipeline facilities and Gathering and Boosting facilities only.
-0046
"Miles of natural gas transmission pipeline."
This is reported in the GHGRP for transmission pipeline facilities per (aa)(11)(vi). This is a redundant information request and should be removed from the ICR.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Other/General

-0061
Add `Well Classification' for Onshore Production: In order to appropriately classify data for Onshore production, the GOR categories used for identifying the Part 2 recipients should be included within the Survey for identification.
EPA agrees with the commenter and is implementing this revision.
/-0031
For natural gas pipelines, limit the `facility' to one state rather than the entire pipeline length. Performing a field count on all equipment along an entire, multi-state length of pipe would be costly and resource inefficient.
EPA agrees with the commenter and is implementing this revision.
-0068
Add the following questions:
 For production facilities, quantity of produced water (thousand bbl/year in the 2015 calendar year).
 Quantity of natural gas leaving the facility by pipeline (sales) in the 2015 calendar year (thousand standard cubic feet).
 Quantity of natural gas utilized at the facility in the 2015 calendar year (thousand standard cubic feet).
 Quantity of natural gas leaving the facility (for sales) other than by pipeline (e.g., trucked CNG) in the 2015 calendar year (thousand standard cubic feet).
 Quantity of natural gas vented from the facility in the 2015 calendar year (thousand standard cubic feet).
 Quantity of natural gas flared from the facility in the 2015 calendar year (thousand standard cubic feet).
 If transmission compressor station, pipeline mileage from immediate compressor station upstream
 If transmission compressor station, pipeline mileage from immediate compressor station downstream
 If transmission compressor station, number of isolation valves upstream up to immediate compressor station upstream
 If transmission compressor station, number of isolation valves downstream up to immediate compressor station downstream
 If gathering and boosting facility, number of wells connected to the station
 If gathering and boosting facility, pipeline mileage to the nearest distance downstream to the next GB facility, transmission compressor station, or processing plant
EPA has amended Table 2 to include "For production facilities, quantity of produced water (thousand bbl/year in the 2015 calendar year)" and "Quantity of natural gas vented from the facility in the 2015 calendar year (thousand standard cubic feet)."

Well Site Tab

Table 1: Well Site Information

-0061
Distance from field office should be clarified to specify that the distance requested should be provided in road miles.
EPA has amended Table 1 to request "Driving distance from field office (road miles)."
-0061
Distance to the nearest natural gas transmission or gathering pipeline is not an appropriate data element for inclusion in the ICR. This data element should be limited in scope, as it is not pertinent to all facilities. The information should only be requested for oil wells with associated gas that are not connected to a gas gathering line.
EPA has clarified that this information should only be provided if well sites are not connected to a gathering and boosting or transmission pipeline.  EPA has also requested reasoning for any lack of connection.
-0061
`How frequently is well site visited by field office personnel?' should be updated to `How frequently does the well site receive scheduled, routine visits by field office personnel?'
EPA has amended "How frequently is well site visited by field office personnel?" to allow a picklist of options to choose.
-0061, 49
`Is land owned or leased?' should be removed from the ICR. Land leased/owned status has no relevance to emissions or cost of controls.
 If EPA requires this information, then it must make clear what value this information will provide to justify the time and expense.
EPA has amended "Is land owned or leased?" to allow a picklist of options.
-0061
Regulations listed must be updated. Regulations should be limited to those that may apply to individual wells, since they may not apply uniformly to all wells on location.
This list should be updated to `State / Local Environmental Regulations or Permit'.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
EPA requests the average age of wells onsite. There is no emissions related benefit to EPA with this value. Therefore, it is recommended that EPA strike the request for this information.
EPA has amended the ProdnWells Tab to request "What is the age (years) of the well at the well site?" on a per Well ID basis.
-0068
Delete "What is the average age of the wells at the well site?" from Table 1 and move to Table 2.
EPA appreciates the comment and will implement as suggested.
-0061
`How are produced waters managed?' should be removed from the well information. If it is stored onsite, relevant data will be provided under storage tanks.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
`Number of wells at the well site' can be determined by the number listed in Table 2. General Well Information. This data element should be removed from Table 1.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Add the following questions to Table 1:
 Specify connectivity of wells: gathering pipeline, transmission pipeline, distribution pipeline, end user, not connected
 If yes, what is the pipeline pressure?
 Reservoir/formation pressure
 Who owns the mineral rights; private, federal, or tribal?
 Is there a combustion device on or near the site?
 If combustion device is on or near site, what type of device is it? (open flare, enclosed flare, thermal combustor, open pit flare, other)
 If combustion device is on or near site, is it operational?
 If combustion device is near site, what is the distance of the nearest flare?
 If combustion device is a flare, does it have a continuous pilot or electronic ignition device?
 If the combustion device is a flare, does it have a monitor to ensure a continuous flame?
 If the flare has a monitor to ensure continuous flame, describe the device used.
 Is the site connected to a grid?
 If not, how far is the nearest grid connection (in miles)?
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Table 2: General Well Information

-0061, 59
The `Well Type' and `Date of last produce for shut-in or abandoned wells' should be removed because the survey should only cover active wells. If EPA continues to collect `capped or abandoned wells' counts in Part 2, then the instructions should clarify that this count only applies to facilities that had active production at the end of 2015.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061, 49, 48, 59
Downhole configurations can be much more complicated than this data describes and unnecessary to determine emissions. Well bore depth, length, shut-in pressure, casing diameter, and tubing diameter are not sufficient to quantify emissions, may not adequately characterize complex downhole configurations, and should not be requested.
 Information like well depth and well bore length may not be straightforward to obtain. Many wells have multilateral designs like tree roots. Others have capillary strings to enable production from multiple zones without comingling the oil, natural gas, and water from each zone. A capillary string well produces to multiple separators connected to their own tank batteries, with multiple facilities receiving fluids from that single well. Some of the requests in this section are only suitable for single well bores, and can pose problems for other configurations.
 For older producing wells much of the data requested in this section may be non-existent.
EPA has amended Table 2 to include "Type of Well Bore" to allow for further clarification on downhole configurations.
-0064
Acceptable methods to determine production rates need to be clarified. For California operations, wells undergo scheduled tests to measure the volume of oil, produced water, and gas over a short time period. This data is used to allocate the aggregate volume of oil metered at the sales point back to the individual well. It is likely that in most cases, a well test will not be available over the last 30 days of operation. The EPA should specify how to complete this entry when there are no meters on the individual wells.
Companies should provide metered data where available, otherwise use best available data when responding to the ICR.

EPA has expanded "Where is produced gas monitored?" to include an offsite option.
-0061, 68
`Where is gas or oil/condensate monitored?' should be removed.
Companies should provide metered data where available, otherwise use best available data when responding to the ICR.

EPA has expanded "Where is produced gas monitored?" to include an offsite option.
-0061
Early production data (i.e., rates, GOR, and gas composition) is often not available for new wells. At a minimum, an option for `Not Available' is needed. If it is available, the month/year of the data should be reported.
Companies should provide best available data when responding to the ICR.
-0061
Only the `Most Recent Measurement of Produced Gas Composition' should be included.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
EPA should designate a method based on technical feasibility for determining GOR after flowback or change the request to indicate an "estimated" GOR value for periods after the first 30 days of production.
Companies should provide best available data when responding to the ICR.
-0064, 48
The Part 2 "Well Sites" section requires three different GOR and produced gas composition values for each well. Some explanation should be provided to clarify how this value should be determined. It is unlikely that this data will be readily available for each well.
Companies should provide best available data when responding to the ICR.
-0068
The composition of gas typically does not change drastically within a year, therefore asking for current gas composition is unwarranted. Remove the following from Table 2:
 Current Produced Gas Composition - CO2 (% by vol)
 Current Produced Gas Composition - CH4 (% by vol)
 Current Produced Gas Composition - C2H6 (% by vol)
 Current Produced Gas Composition - VOC (% by vol)
 Current Gas to Oil Ratio
EPA has amended Table 2 to request "Produced Gas Composition in first 30 days production" and "Produced Gas Composition in calendar year 2015 or last year of operation."
-0049
EPA ask first if an extended gas analysis has been performed from a particular well and if so, then an operator can provide that analysis.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049
EPA should remove the request to produce ethane % by volume from the ICR. Ethane is not considered a VOC.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Table 2: Remove reference to "Oil" from "Oil Producing Wells Only - API gravity of produced oil." Replace with "liquids".
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061
In Table 2. General Well Information, a column should be added, `Reason for gas venting or flaring'. If an oil well identities that `Disposition of casing head gas' is vented to atmosphere or vented to flare, then operators should identify a reason for why gas is not sold. The pick list should be limited to the following options:
 No permit for pipeline to tie well to system
 Insufficient gas quantity/pressure
 Poor gas quality/Does not meet specifications
 No contract in place
 Right-of-way acquisition
 Transmission line approval
 Transmission line construction
 Exploration Well
 Pipeline and/or plant capacity constraints
 Other, specify
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0068
Add the following questions to Table 2:
 Age of the well (years)
 Is gas metered on or off of the well site?
 Is oil metered on or off of the well site?
 Average Produced Gas Composition in first 30 days production - CO2 (% by vol)
 Average Produced Gas Composition in first 30 days production - CH4 (% by vol)
 Average Produced Gas Composition in first 30 days production - C2H6 (% by vol)
 Average Produced Gas Composition in first 30 days production - VOC (% by vol)
 Average Produced Gas Composition in first 30 days production  -  HAP (% by vol)
 Average Produced Gas Composition in first 30 days production - Inerts (% by vol)
 Average Produced Gas Composition in calendar year 2015 or last year of operation - CO2 (% by vol)
 Average Produced Gas Composition in calendar year 2015 or last year of operation  -  H2S (% by vol)
 Annual average wellhead pressure during first year of production (psig)
 Annual average wellhead pressure in the last year of production (psig)
 Average Produced Gas Composition in calendar year 2015 or last year of operation - CH4 (% by vol)
 Average Produced Gas Composition in calendar year 2015 or last year of operation - C2H6 (% by vol)
 Average Produced Gas Composition in calendar year 2015 or last year of operation - VOC (% by vol)
 Average Produced Gas Composition in calendar year 2015 or last year of operation  -  HAP (% by vol)
 Average Produced Gas Composition in calendar year 2015 or last year of operation - Inerts (% by vol)
 Average Produced Gas Composition in calendar year 2015 or last year of operation  -  H2S (% by vol)
EPA has amended Table 2 to include "Well pressure in first 30 days production (psig)" and has expanded gas compositions.

Table 3: Well Completion and Workover Information

-0061, 49, 59
Table 3 will provide limited or redundant information and should be removed from the Part 2 Survey.
 The information on well completions for hydraulically fractured and refractured wells is already covered under NSPS OOOOa; therefore, this request for information is redundant.
 Workovers are typically intended for maintenance of downhole equipment. There is typically no venting associated with workovers since the well cannot be active for safety purposes during maintenance and the data requested may not be readily available.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0049, 48, 59
Well completion data requested could likely be obtained through the appropriate state records.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0050, 49, 48, 59, 61
EPA should remove "date of next workover" from ICR, as it requires operators to predict reservoir conditions, market conditions, availability of equipment, availability of capital, etc.
 The `Date of Last Workover' may not be available if the well was acquired from another operator and `Anticipated date of next workover' cannot always be anticipated, as workovers are mainly initiated as an as needed maintenance practice.
EPA has removed "Anticipated date of next workover."
-0068
Add the following questions to Table 3:
 Average duration of completion (hours)
 Number of workovers in last 5 years
 Average duration of workover (hours)
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.

Table 4: Well Testing, Venting, and Liquids Unloading Information
-0061, 59, 68
At a minimum, EPA should delete `/venting' from the column title `Date of last well testing/venting'. This will help eliminate confusion between well capacity testing and `liquids unloading', which is covered in other columns of Table 4. Well testing does not directly equate to venting.
EPA has removed "/venting" from the title of Table 4.
-0068
Table 4 "Controls used for well testing":
 Change question to "Controls used for last well testing"
 It is unclear what the difference between "Vent to other control" and "Capture for recovery/sales" is, suggest only keeping the latter; also add "Capture and recovery/use at site"
EPA has amended Table 4 to request "Controls used for last well testing."
-0061
Include `Other' in the pick list for `Controls used for well testing'. While EPA has included the obvious choices in the pick list for Column E, the variety of operations in the oil and gas industry makes it likely that a different control option exists.
EPA has considered and evaluated the impacts of this comment and has decided not to pursue any further action.
-0061, 59
The information included in the draft ICR on liquids unloading will not provide EPA with adequate information to estimate methane emissions. Well engineers and operators must have the flexibility to employ the appropriate tools at the appropriate times to manage wellbore liquids. If the information remains in the Part 2 Survey, numerous changes are required: