I am addressing the Oil and Natural Gas Sector Leaks whitepaper.

The paper should emphasize that some equipment, such as condensate tanks, that are not designed to hold liquids and gasses under pressure cannot be made to stop leaking with simple fixes. Condensate tanks that hold liquids with dissolved gasses that flash when the pressure is lowered from the well pressure to the tank pressure are designed to vent these gasses to the atmosphere. The only way to stop this is to use multi-stage separators so that flashing occurs during separation, and to rout flash emissions to the gas collection system instead of the tank.

-- 
Dale Wells
Modeling, Meteorology, and Emission Inventory Unit
Technical Services Program
Air Pollution Control Division
Colorado Department of Public Health and Environment
APCD-TS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
303-692-3237| dale.wells@state.co.us

