2017-05-25_REVISION - C1996083 - Laserfiche WebLink

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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 77 • Requiring centralized or consolidated gas processing facilities. • Replacement of wet seals with dry seals in centrifugal compressors; • Monitoring and replacement of rod packing systems in reciprocating compressors; • Installation of well deliquification systems such as plunger lifts; • Use of closed loop process for “blow-down” emissions; • Replacement of hi-bleed with low- or no-bleed and other low-emission equipment for pneumatic devices; Mandatory leak detection and repair programs. There must be much tighter commitments for these “assumed” measures, and these measures must be revised to include the following amendments and additions: • Use of reduced-emission completion practices including “routing all saleable quality gas to a flow line (rather than permitting some emissions to be vented or flared) • Reduction in the pace or phasing of development to provide the time required to bring capture and sales line infrastructure into alignment with production. • Curtailment of production when sufficient capture and sales line infrastructure is not available. • Electric compression • Use of dry seals on centrifugal compressors • Periodic replacement of rod packing systems on reciprocal compressors • Capture and sale of gas emitted from drilling, completions, production testing, pipeline maintenance, liquids unloading, and oil wells (associated gas) • Replacement of existing high- or intermittent-bleed pneumatic controllers with low- or no-bleed controllers, and installation of low- or no-bleed controllers in new construction • Installation of emissions controls on all storage tanks • Equipment replacement of TEG dehydrators with dessicant dehydrators