From: Spells, Charlene 
Sent: Tuesday, October 18, 2016 11:01 AM
To: 'Aaron_L_Szabo@omb.eop.gov' <Aaron_L_Szabo@omb.eop.gov>
Cc: Cozzie, David <Cozzie.David@epa.gov>; Moore, Bruce <Moore.Bruce@epa.gov>; Schillo, Bruce <Schillo.Bruce@epa.gov>
Subject: RE: Summary of Interagency Comments under EO12866 and 13563 for EPA Final Guide -- Control Technique Guidelines for the Oil and Natural Gas Industry (RIN 2060-ZA22)

Aaron,

Attached is the revised response to interagency comments in RLSO.

Charlene E. Spells
U.S. EPA
OAQPS/SPPD 
RTP, NC 27711
Phone:  (919) 541-5255  Fax:  (919) 541-3470
spells.charlene@epa.gov

From: Spells, Charlene 
Sent: Thursday, August 25, 2016 5:38 PM
To: 'Aaron_L_Szabo@omb.eop.gov' <Aaron_L_Szabo@omb.eop.gov>
Cc: Cozzie, David <Cozzie.David@epa.gov>; Moore, Bruce <Moore.Bruce@epa.gov>; Schillo, Bruce <Schillo.Bruce@epa.gov>
Subject: RE: Summary of Interagency Comments under EO12866 and 13563 for EPA Final Guide -- Control Technique Guidelines for the Oil and Natural Gas Industry (RIN 2060-ZA22)

Aaron,

Below our mark up of language from the most recent response to interagency comments.

      The RACT recommendation for fugitive emissions from well sites addresses well sites with an average production of greater than 15 barrel equivalents per well per day (15 barrel equivalents).  We received comments supporting our approach to not establishing RACT for wells with an average production less than 15 barrel equivalents, as well as comments encouraging EPA to establish RACT for these low production well sites.  As we indicated in the New Source Performance Standards (NSPS) and in our review of the comments submitted on the CTG, we did not receive data showing that distinguishing the potential emissions from low production well sites from the potential emissions associated with than non-low production well sites.  Rather, the data information that were was provided on the NSPS indicated that the potential emissions from these well sites could be as significant as the emissions from non-low production well sites because the type of equipment and the well pressures are more than likely the same.  However, the EPA notes that the draft CTG did not provide sufficient detail on the scope and impacts of including these low production wells in the CTG to allow the public an opportunity for extensive, detailed comments on their inclusion.  Thus, given the EPA's approach to the development of the CTG, which featured the opportunity for the public to fully engage on this issue with regard to the CTG, and in light of the absence of meaningful detail on scope and impacts, the EPA has decided not to establish RACT for wells with an average production of less than 15 barrel equivalents at this time.  The EPA notes, in contrast, that for the New Source Performance Standards, the EPA was able to move forward with standards for the low production well sites because the Agency provided more discussion and analysis of the scope and impacts associated with low production wells.  In addition, unlike the New Source Performance Standards, the RACT determination specifically focuses on reduction of VOC emissions, rather than emissions of both VOCs and methane. 

Charlene E. Spells
U.S. EPA
OAQPS/SPPD 
RTP, NC 27711
Phone:  (919) 541-5255  Fax:  (919) 541-3470
spells.charlene@epa.gov

From: Szabo, Aaron [mailto:Aaron_L_Szabo@omb.eop.gov] 
Sent: Tuesday, August 23, 2016 5:56 PM
To: Spells, Charlene <Spells.Charlene@epa.gov>
Cc: Cozzie, David <Cozzie.David@epa.gov>; Szabo, Aaron <Aaron_L_Szabo@omb.eop.gov>
Subject: Summary of Interagency Comments under EO12866 and 13563 for EPA Final Guide -- Control Technique Guidelines for the Oil and Natural Gas Industry (RIN 2060-ZA22)

Below please find the summary of interagency comments under EO 12866 and 13563 for the EPA draft final guide entitled, "Control Technique Guidelines for the Oil and Natural Gas Industry" (RIN 2060-ZA22) in response to the most recent response to interagency comments. 

      The RACT recommendation for fugitive emissions from well sites addresses well sites with an average production of greater than 15 barrel equivalents per well per day (15 barrel equivalents).  We received comments supporting our approach to not establishing RACT for wells with an average production less than 15 barrel equivalents, as well as comments encouraging EPA to establish RACT for these low production well sites.  As we indicated in the New Source Performance Standards, we did not receive data showing that low production well sites have lower VOC emissions than non-low production well sites.  Rather, the data that were provided indicated that the potential emissions from these well sites could be as significant as the emissions from non-low production well sites because the type of equipment and the well pressures are more than likely the same.  However, the EPA notes that the draft CTG did not provide sufficient detail on the scope and impacts of including these low production wells in the CTG to allow the public an opportunity for extensive, detailed comments on their inclusion.  Thus, given the EPA's approach to the development of the CTG, which featured the opportunity for the public to fully engage on this issue with regard to the CTG, and in light of the absence of meaningful detail on scope and impacts, the EPA has decided not to establish RACT for wells with an average production of less than 15 barrel equivalents at this time.  The EPA notes, in contrast, that for the New Source Performance Standards, the EPA was able to move forward with standards for the low production well sites because the Agency provided more discussion and analysis of the scope and impacts associated with low production wells.  In addition, unlike the New Source Performance Standards, the RACT determination specifically focuses on reduction of VOC emissions, rather than emissions of both VOCs and methane. 


Aaron L. Szabo
Policy Analyst
Office of Information and Regulatory Affairs
Office of Management and Budget
202-395-3621
Aaron_L_Szabo@omb.eop.gov


