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Gas STAR Gold Program: Proposed Framework
Executive Summary
Following the President's Climate Action Plan, the White House Strategy to Reduce Methane Emissions,
released in March 2014, included enhancing EPA's successful voluntary Natural Gas STAR Program as
one of the key approaches in the oil and natural gas sector. As an additional element of its successful
Natural Gas STAR Program, EPA is proposing a voluntary, facility-based, methane-reduction program for
leading oil and gas companies. The proposed Gas STAR Gold Program will recognize facilities throughout
the oil production and the entire natural gas value chain - production, gathering and boosting,
processing, transmission, storage, and distribution - that achieve "Gas STAR Gold" status. It is
proposed that facilities would achieve Gas STAR Gold status by implementing a comprehensive suite of
protocols for reducing methane emissions through readily-available, cost-effective technologies and
best practices.
The key goals of the Gas STAR Gold Program are as follows:
1.	Showcase facilities that are already achieving methane emission reductions;
2.	Encourage facilities to identify and implement opportunities to achieve further methane
emission reductions;
3.	Create a framework for credible, transparent and consistent reporting on facilities that can be
easily understood and compared; and
4.	Recognize progress that companies are achieving in emission reductions relative to their overall
operations.
This framework document outlines the proposed program elements, describing how the program would
operate and lists the technical protocols that would form the basis of the program. EPA welcomes
feedback from stakeholders both through discussions and written feedback submitted to EPA through
the Natural Gas STAR website. EPA plans to evaluate and incorporate this feedback into a revised final
framework document to be published in fall 2014. EPA anticipates formally launching the program by
the end of 2014, with the first full annual cycle beginning in 2015.
Introduction
Methane is an important short-lived climate pollutant and a potent greenhouse gas, with over 20 times
the global warming potential of carbon dioxide over a 100 year time horizon. The oil and gas sector is
one of the leading sources of anthropogenic methane emissions in the United States, with annual
emissions of approximately 160 million metric tonnes of carbon dioxide equivalent (MMTC02e) in 2012.
Since 1993, EPA's Natural Gas STAR Program has successfully collaborated with the oil and natural gas
industry on implementation of cost-effective methane emission reduction technologies and practices.
Through 2012, Partner companies have reported voluntary methane emission reductions of over one
trillion cubic feet (over 400 MMTC02e).
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The Natural Gas STAR Program provides a platform to encourage oil and natural gas Partner companies
to implement and share information on cost-effective methane emission reduction technologies and
practices and create a record of their voluntary achievements. Gas STAR Partners have identified over
50 specific cost-effective technologies and practices. However, significant opportunities remain to
encourage broader and deeper penetration of methane emission reduction technologies and practices
in the industry.
Goals of the Gas STAR Gold Program
The proposed Gas STAR Gold Program would complement and build upon the current Natural Gas STAR
Program, which will continue to work with industry Partners to reduce methane emissions through
voluntary actions. The Gas STAR Gold Program would be an additional element of the Natural Gas STAR
Program; it would be a voluntary, facility-based, methane emission reduction program to highlight
methane reductions by leading facilities.
The proposed Gas STAR Gold Program will recognize leading facilities throughout the oil production
segment and the entire natural gas value chain - offshore and onshore production, gathering and
boosting, processing, transmission, storage, and distribution segments. Participating facilities would
achieve Gas STAR Gold status by implementing a comprehensive suite of protocols for reducing
methane emissions through readily-available, cost-effective technologies and best management
practices. The Gas STAR Gold Program will create a credible, transparent, comparable, and verifiable
mechanism to incentivize and document achievement of facility-level implementation of methane
emission mitigation practices.
The goals of the proposed Gas STAR Gold Program are as follows:
1)	Showcase facilities that are already achieving methane emission reductions;
2)	Encourage facilities to identify and implement opportunities to achieve further methane
reductions;
3)	Create a framework for credible, transparent, and verifiable reporting on facilities that can be
easily understood and compared; and
4)	Recognize progress that companies are achieving in emission reductions relative to their overall
operations.
Gas STAR Gold Protocols
The proposed Gas STAR Gold protocols are intended to address high-emitting methane emissions
sources using readily-available cost-effective technologies and practices. EPA has proposed more than a
dozen high-emitting methane sources at petroleum and natural gas facilities that would form the core of
the Gas STAR Gold Program (see Appendix) in the following segments of the oil and natural gas industry:
offshore petroleum and natural gas production (Off P), onshore petroleum and natural gas production
(On P), gathering and boosting (GB), onshore natural gas processing (Pc), onshore natural gas
transmission (T), onshore natural gas storage (S), LNG storage (LNG S), LNG import & export (LNG l&E),
and natural gas distribution (D).
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For each emission source, EPA has identified a specific set of proposed "Gas STAR Gold protocols" based
on readily-available best practices and technologies that have been identified through the Natural Gas
STAR Program and, where applicable, existing regulations such as New Source Performance
Standards. In cases where multiple technologies or practices are identified under a specific protocol,
Table 2 lists them in rank order based on applicability.
EPA proposes that, to achieve Gas STAR Gold status, a facility would implement all applicable protocols
in a given year unless there is an exemption clarified in the protocol, for example, for safety or
emergency reasons.
EPA proposes that for the purpose of the Gas STAR Gold Program, facility definitions would be
consistent with definitions in the Greenhouse Gas Reporting Program.
Facilities would document their achievement through annual reporting of relevant supporting data to
EPA.
In the near term, EPA plans to release a detailed technical background document to provide further
information on the proposed protocols, implementation practices, definitions, and the data elements to
be submitted to EPA annually to achieve Gas STAR Gold status for each facility.
Corporate level (platinum) achievement. EPA proposes to recognize, at the corporate level, companies
for superior achievement based upon their total facility-level Gas STAR Gold status. EPA proposes a
"Gas STAR Platinum" status for recognizing companies that achieve Gold status exceeding a certain
proportion of their facilities, e.g., at least 90% of their facilities in a given year.
Maintaining the current Natural Gas STAR Program. EPA appreciates the feedback we have received
from our Partners about the value of the Natural Gas STAR Program. EPA plans to maintain the current
Natural Gas STAR Program and will continue core Natural Gas STAR Program activities such as
technology transfer workshops. EPA looks forward to continuing to work with our Natural Gas STAR
Partners to achieve methane emission reductions.
Gas STAR Gold Program Implementation
EPA proposes a streamlined process for facilities to achieve Gas STAR Gold status:
1) Letter of Intent
A company would sign a standardized agreement that signifies the company's intent to work
collaboratively with EPA to achieve Gold status at one or more facilities.
2) Implementation Plan
The company would develop an implementation plan for each of its facilities seeking Gas STAR Gold
status. This plan would include a specified timeframe for protocol implementation for each facility.
EPA proposes that participating companies will reapply or demonstrate continued application of all
applicable Gold protocols for each facility annually, and will also continually expand the number of
facilities that are working towards or achieving Gas STAR Gold status. The implementation plan
would outline the companies' plans for the coming year(s) and would be updated as needed. EPA
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proposes that the Implementation Plan be submitted by companies within three months of
submitting a Letter of Intent.
3) Annual Reporting
Each facility seeking Gas STAR Gold status would certify that all applicable protocols were
implemented for the reporting period (annually) and would submit any appropriate data to
corroborate protocol implementation as specified in the forthcoming protocol technical background
document. EPA will work to ensure that the reporting is as simplified as possible, akin to a facility-
level "checklist" plus supplemental information. EPA is evaluating options to ensure that electronic
reporting is streamlined with existing data and reporting mechanisms wherever possible.
EPA proposes an annual reporting cycle (e.g., annual reports on Gas STAR Gold facilities due each
spring).
4) EPA Verification
Based on annual reports and data submitted, EPA will evaluate and verify Gas STAR Gold status for
each facility. To the extent possible, EPA will leverage existing data and information (e.g., facility
data reported to EPA through the Greenhouse Gas Reporting Program). For specific emissions
sources or protocols (e.g., those for which relevant information is not reported through the
Greenhouse Gas Reporting Program), EPA may require additional data to document and verify
achievement of the protocols. To ensure programmatic credibility, EPA will develop transparent
systems and processes for annual reporting and verification of Gas STAR Gold facilities. EPA plans to
notify each company or facility of the status of its evaluation and verification process and would
offer companies the opportunity to supply additional information as appropriate. EPA proposes that
all Gas STAR Gold-related facility data be made public.
5) Gold Status Achievement and Recognition
EPA will create a dedicated Gas STAR Gold Program website that will showcase all Gas STAR Gold
facilities and will highlight companies' achievements relative to their overall operations. In order to
maximize program credibility, the Gas STAR Gold Program will have to be as transparent as possible
regarding data and the verification process.
In the near term, EPA will release prototypes of the letter of intent, implementation plan, annual
report, and the Gas STAR Gold recognition webpage.
Gas STAR Gold Partner Benefits
Facilities and companies that achieve Gold and Platinum status will be publicly recognized for their
progress through a variety of mechanisms including the EPA website, EPA conferences, and other
outlets. For example, at the Natural Gas STAR Annual Implementation Workshop, EPA will distinguish
companies that achieve program milestones, such as those companies that submit letters of intent to
join Gas STAR Gold; those that have achieved Gold status for one or more facilities; and those that have
achieved Platinum status at the corporate level.
EPA will develop a Gas STAR Gold label, similar in concept to the Energy STAR label, that Gold status
facilities and companies would be authorized to use to promote their achievements. EPA will also
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EPA will work with facilities and companies to promote their Gold and Platinum status in other ways
such as through annual reports, sustainability indices, and shareholder events.
Launch of Gas STAR Gold Program
EPA plans to host an event in Washington, DC, by the end of 2014 to recognize companies that have
committed to become Charter Partners of the Gas STAR Gold Program by signing a Letter of Intent.
The first full annual cycle of the program will begin January 1, 2015, and the first annual reporting cycle
is proposed for spring 2016. Companies are welcome to join the program by signing a Letter of Intent at
any point.
Stakeholder Feedback Process
Following publication of the White House Strategy to Reduce Methane Emissions, EPA launched a
process for stakeholder feedback on ail aspects of the proposed program. EPA looks forward to working
collaboratively with industry, states, federal agencies, NGOs, and others to build a robust Gas STAR Gold
Program that will promote the best methane emission reduction technologies and practices, provide
credible and transparent performance data, benefit industry by generating additional revenue and
increasing safety, and protect public health and the environment.
Stakeholders can submit feedback in several ways:
1)	Through the Natural Gas STAR Program website: epa.gov/gasstar/contactus.html
2)	Directly to Roger Fernandez at 202-343-9386 or via email: fernandez.roger@epa.gov
3)	Through the forthcoming Gas STAR Gold website, which will include a public feedback section.
EPA will launch a Gas STAR Gold website in May 2014 where all documents and information related to
the Gas STAR Gold program will be available.
In addition, there will be opportunities for discussions through in-person meetings, webinars, and
teleconferences. EPA will be conducting targeted outreach to stakeholders, including, oil and natural
gas companies (including Natural Gas STAR Partners), industry trade associations and organizations,
NGOs, and States. This will include a presentation at the Natural Gas STAR Annual Implementation
Workshop to be held in May 2014, two webinars to be scheduled in June 2014, and an in-person
meeting to be held June 25, 2014 in the Washington, DC, area.
EPA will accept carefully consider and evaluate all feedback received through July 31, 2014. To the
extent appropriate and applicable and consistent with the aims of the Gas STAR Gold Program, this
feedback will be incorporated into a revised framework document to be released in the autumn of 2014.
EPA requests feedback from stakeholders on the all elements of the proposed Gas STAR Gold Program,
especially the following issues:
1) Program Recognition and Incentives
a) In addition to recognition through the Program, what are the key incentives for companies to
participate in this enhanced program?
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b)	In addition to recognizing Gas STAR Gold facilities through the EPA web site, conferences, and
other outlets, what are other suggestions or mechanisms for EPA to acknowledge and promote
facility Gold-level achievements?
c)	How can EPA best market this program to key stakeholders including company management and
boards, state and local regulators, NGOs, investors, shareholders, and the public?
d)	Are there any suggestions regarding the proposed program name: Gas STAR Gold Program?
e)	Are there other models or approaches that would be effective at incentivizing voluntary emissions
reductions in this sector?
f)	How should the program incorporate recognition for actors or partners that are not facilities or oil
& natural gas companies (e.g., public utility commissions or states)?
2)	Program Implementation
a)	What facility barriers exist to achieving "Gold" recognition that EPA can assist in overcoming?
b)	EPA is proposing that facilities would need to achieve 100% implementation of all applicable
protocols at each facility to earn Gas STAR Gold status (with exceptions for safety or emergency
situations). We welcome feedback on other thresholds or mechanisms for achieving Gas STAR
Gold status at the facility level that maintains high levels of integrity, verifiabiiity, and methane
emissions reductions.
c)	EPA seeks feedback on specific aspects of implementing the Program at the facility level including
handling acquisitions and divestitures for the production segment.
d)	EPA plans to leverage existing data and reporting mechanisms (such as the Greenhouse Gas
Reporting Program) wherever possible. Are there particular ideas or suggestions for EPA to
streamline reporting in a way that reduces burden to the facilities?
e)	EPA seeks feedback on the proposed frequency of annual reporting for Gas STAR Gold facilities.
Would a rolling reporting system (with a corresponding rolling certification of Gas STAR Gold
facilities) be preferable?
f)	EPA proposes that companies achieve or exceed Gas STAR Gold status at 90% of their facilities to
earn "Platinum" status. EPA seeks feedback on the proposed threshold for companies to earn this
status.
g)	EPA seeks feedback on the appropriate time frame before a company should submit its
Implementation Plan (e.g., 3 months after submitting Letter of Intent, and annual updates
thereafter).
h)	EPA seeks feedback on the program's provisions for data transparency and verification (e.g., EPA
verification versus third party verification).
3)	Existing Regulatory Frameworks
a) It is the intent of Gas STAR Gold Program to meet or exceed existing voluntary and mandatory
methane-related voluntary and regulatory frameworks. Do any of the proposed protocols conflict
with existing regulations or frameworks?
4)	Proposed Protocols
a) Are appropriate emissions sources targeted in these protocols?
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b)	Are appropriate best management practices, technologies and/or emission mitigation targets used
in the protocols?
c)	Should EPA consider any additional emissions sources and/or associated protocols?
d)	EPA seeks feedback on other mechanisms to incentivize facilities to achieve the methane
emissions reductions, especially from the largest sources of methane.
e)	For the local distribution segment, please provide feedback on performance goals for specific
sources, such as cast iron pipe replacement, that can expedite the pace of methane emissions
reductions in the context of existing regulatory frameworks.
f)	For local distribution companies with limited or no cast iron or exposed steel pipe, EPA seeks
feedback on how to further methane emissions reductions that would be appropriate for "Gold"
recognition.
g)	Casinghead gas is a large methane emissions source in certain locations. EPA is seeking feedback
regarding the proposed protocols for this source.
h)	EPA recognizes three major phases in the life of an unassociated gas well when liquids unloading is
necessary; (a) when the reservoir has sufficient energy to lift the liquids with or without a plunger
lift system, (b) when the reservoir has energy, but not sufficient enough to lift a plunger plus a
reasonable liquid load to the sales line; and (c) when the reservoir has insufficient energy to expel
liquids by any means except to pump the liquids separately from gas flow. EPA is seeking feedback
on the feasibility of capturing gas from well liquids unloading in phases (b) and (c) in the life of a
gas well.
i)	For cast iron pipeline and unprotected steel pipeline distribution mains fugitive emissions sources,
EPA is seeking feedback on the feasibility and economics of replacing, lining, or sealing, either
internally or externally, these pipelines to mitigate emissions. EPA is also seeking feedback on the
effectiveness of lining and sealing options in mitigating methane emissions.
j) EPA has suggested an annual and bi-annual inspection frequency for detecting and fixing fugitive
emissions from onshore production and gathering and boosting facilities based on the absolute
tonnage of natural gas emissions. EPA recognizes that such a requirement automatically requires
very large basins to fall into the bi-annual frequency requirements. Other possible options include
but are not limited to considering using an emissions intensity (emissions divided by production
from the facility) approach to determine the survey frequency.
k) EPA welcomes feedback on ways in which the program can be designed to foster continual
improvement, i.e., through specific mechanisms and timeframes for assessing the program
elements and making appropriate modifications to the protocols to reflect the evolving industry
state-of-the-art.?
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Schedule for Program Outreach and Launch
Table 1: Gas STAR Gold Program Timeline for Outreach and Launch
Date
Milestone
Through May 11, 2014
Informal outreach / Stakeholder discussions
May 12, 2014
Presentation and discussion of Gas STAR Gold Program at


Natural Gas STAR Annual Implementation Workshop - San


Antonio, TX
Through July 31, 2014
Stakeholder Feedback Period

Through July 31, 2014
Stakeholder Meetings upon Request

June 4, 2014
Proposed Gas STAR Gold Webinar

June 13, 2014
Proposed Gas STAR Gold Webinar

June 25, 2014
Gas STAR Gold Meeting - Washington, DC

July 31, 2014
Close of Feedback Period
Autumn 2014
Revised Gas STAR Gold Framework
Through December 2014
Charter Partner Sign-up
December 2014
Formal Launch of Gas STAR Gold Program
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Appendix A. Proposed Gas STAR Gold Protocols
Protocol
Emission
Source
Off P
On P
GB
PC
T
S
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
i
Associated Gas
Y
Y
Y






1. Recover for beneficial use all associated gas produced
from the reservoir, regardless of well type, except for gas
produced from wildcat and delineation wells or as a result
of system failures and emergencies. Beneficial use does
not include flaring.
2
Casinghead Gas

Y







This protocol applies to each well with annual average emissions
of casinghead gas greater than or equal to 60 grams per hour1
of natural gas.
1.	For facility with existing gas capture system, or low
pressure gas system, or gas capture system being installed
for another protocol, capture casinghead gas for beneficial
use. Beneficial use does not include flaring.
2.	If (1) does not apply, for facility where emissions can be
economically captured for beneficial use, capture
casinghead gas. Beneficial use does not include flaring.
3.	If (1) and (2) do not apply, for facility with flare
connection/header existing on or adjacent to the well pad
where the casinghead is located or being installed for
another protocol, route casinghead gas to flare.
4.	If (1), (2), and (3) do not apply, install a flare and route
casinghead gas to installed flare if on a C02 equivalent
basis the amount of gas for maintaining the pilot is less
than the amount of vented casinghead gas.
1
60 grams per hour = Mass emissions equivalent of the 10,000 ppm leak definition for a component in EPA LDAR AWP. Available online at
http://www.epa.gov/ttn/caaa/t3/fr_notices/ldar_fin_121508.pdf
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Protocol
Emission
Source
Off P
On P
GB
PC
T
s
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
3 Centrifugal Y
Compressors -
Wet and Dry
Seals
Y Y
Y
Y
Y Y
Y Y
1.	For centrifugal compressors with wet seal systems,
achieve 95% recovery of uncontrolled methane emissions
for all compressors without using flaring.
2.	For centrifugal compressors with dry seal systems,
maintain venting emissions from the dry seal within 10
percent of the initial design vent rate.
4
Compressor
Blowdowns
Y
Y
Y
Y
Y
Y
Y
Y
Y
1.	For facility with existing gas capture system, or gas capture
system being installed for another protocol, route all non-
emergency blowdown gas to gas capture system for
beneficial use. Beneficial use does not include flaring.
2.	If (1) does not apply, for facility with a low pressure gas
system, or parallel operating compressor, determine
which system is at lower pressure. Route all non-
emergency related blowdown gas to the system at lower
pressure to maximum engineering potential.
3.	When maximum engineering potential is reached, do the
following:
a.	For maintenance blowdowns not requiring complete
evacuation of natural gas from reciprocating
compressors with a positive rod packing sealing
system, retain remaining blowdown gas in the
reciprocating compressor.
b.	For maintenance blowdowns requiring complete
evacuation of natural gas, for existing flare
connection/header or flare being installed for
another protocol:
i.	on or adjacent to the well pad where the
compressor is located for onshore production
segment;
ii.	at the gathering and boosting station for
gathering and boosting segment;
iii.	within or adjacent to facility boundaries for all
other applicable segments;
route remaining blowdown gas to flare.
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Protocol
Emission
Source
Off P
On P
GB
PC
T
s
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
5
Compressor
Starts
Y
Y
Y
Y
Y
Y
Y
Y
Y
1.	For facility where electricity, instrument air, or nitrogen is
available, replace all gas starters with electric, instrument
air or nitrogen.
2.	If (1) does not apply, for facility with existing gas capture
system or gas capture system being installed for another
protocol, route starter vent gas to gas capture system for
beneficial use. Beneficial use does not include flaring.
3.	If (1) and (2) do not apply, for existing flare
connection/header or flare being installed for another
protocol
a.	on or adjacent to the well pad where the compressor
is located for onshore production segment;
b.	at the gathering and boosting station for gathering
and boosting segment;
c.	within or adjacent to facility boundaries for all other
applicable segments; route starter vent gas to flare.
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Equipment
Fugitives above
Ground
Y
Y
Y
Y
Y
Y
Y
Y
Y
L Use Appendix B of this document for the definition of leak
and inspection frequency and conduct comprehensive leak
detection and equipment leak repair as described in the
Air Quality Control Commission Regulation Number 7:
Control of Ozone via Ozone precursors and Control of
Hydrocarbons via Oil and Gas Emissions2 Sections XVII.F.3,
XVII.F.4, XVII.F.5, XVII.F.6, and XVII.F.7.
7
Flares
Y
Y
Y
Y
Y
Y
Y
Y

1. For flares existing within or adjacent to a facility or for
flares being installed for other protocols, use reliable and
continuous ignition systems.
2 Air Quality Control Commission Regulation Number 7: Control of Ozone via Ozone precursors and Control of Hydrocarbons via Oil and Gas Emissions. Available online at
http://www.colorado.gov/cs/Satellite/CDPHE~Main/CBON/1251601911433
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Protocol
Emission
Source
Off P
On P
GB
PC
T
s
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
s
Gas-driven
Pneumatic
Devices (bleed
controllers,
manual
actuators, and
pumps)
Y
Y
Y
Y
Y
Y
Y
Y
Y
1.	Where instrument air or nitrogen is available, install
instrument air or nitrogen driven devices.
2.	If (1) does not apply, for facility where reliable electric
power is available, convert gas-driven pneumatic devices
to instrument air or nitrogen, where economical. Replace
pneumatic pumps with electric pumps, including solar
electric pumps for small units such as chemical and
methanol injection pumps, where economical.
3.	If (1) and (2) do not apply, do the following for all
applications except those requiring high-bleed controllers
for certain purposes, including operational requirements
and safety:
a.	For processing segment, reduce leak rate of
continuous bleed gas-driven pneumatic devices to
zero.
b.	For other segment, reduce leak rate of high-bleed
gas-driven pneumatic devices below 6 scfh.











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Protocol
Emission
Source
Off P
On P
GB
PC
T
s
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
9
Glycol
Dehydrators
Y
Y
Y
Y
Y
Y
Y
Y

This protocol applies to each glycol dehydrator with annual
average emissions greater than or equal to 7,080 grams per
hour3 of natural gas.
For glycol dehydrators with annual average daily throughput
greater than or equal to 0.4 MMSCFD:
1.	For facility with existing gas capture system, or gas capture
being installed for another protocol, route dehydrator
vent(s)4 to gas capture system for beneficial use.
Beneficial use does not include flaring.
2.	If (1) does not apply, route vent from flash tank separator
to low pressure gas system if vent gas volume is less than
or equal to on-site fuel requirements.
3.	If (1) and (2) do not apply, for existing flare
connection/header or flare being installed for another
protocol:
a.	on or adjacent to the well pad where the glycol
dehydrator is located for onshore production
segment;
b.	at the gathering and boosting station for gathering
and boosting segment;
c.	within or adjacent to facility boundaries for ail other
applicable segments;
route vent(s)4 gas to flare.
4.	If (1), (2), and (3) do not apply, maintain glycol circulation
at 110 percent of the optimal circulation rate3 based on
current production rate.
For glycol dehydrators below threshold:
1. Use the protocol for glycol dehydrators above threshold or
maintain glycol circulation at 110 percent of the optimal
circulation rate5 based on current production rate.
3	7,080 grams per hour = Mass emissions equivalent of the 10,000 ppm leak definition for a component in EPA LDAR regulation (60 grams per hourl) multiplied by an average count of 118
components on a glycol dehydrator from Table W-1B to Subpart W of Part 98,
4	Depending on the infrastructure of the facility, the dehydrator vent may be the vent from the flash tank separator, or the vent from the reboiler, or the vent from the vent condenser.
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Protocol
Emission
Source
Off P
On P
GB
PC
T
s
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
10
Hydrocarbon
Storage Tanks
Y
Y
Y
Y
Y




This protocol applies to each hydrocarbon tank with annual
average emissions greater than or equal to 60 grams per hr1 of
natural gas.
For tanks emitting at or above 6 tons per year of methane:
1.	If a gathering or sales line is in place, achieve 95%
recovery of methane emissions using gas capture for
beneficial use. Beneficial use does not include flaring.
2.	If (1) does not apply, achieve 95% reduction of methane
emissions using flaring.
For tanks emitting below 6 tons per year of methane:
1.	If a gathering or sales line is in place, route the gas to an
existing gas capture system or gas capture system being
installed for another protocol for beneficial use. Beneficial
use does not include flaring.
2.	if (1) does not apply, do the following for existing flare
connection/header or flare being installed for another
protocol
a.	on or adjacent to the well pad where the tank is
located for onshore production segment;
b.	at the gathering and boosting station for gathering
and boosting segment;
c.	within or adjacent to facility boundaries for all other
applicable segments;
route vent gas to flare.
li
Liquids
Unloading
Y







1. Install or maintain a closed loop system that eliminates all
methane emissions with the exception of emissions
resulting from system failures or emergency situations.
5 Natural Gas STAR technical documents "Optimize Glycol Circulation And Install Flash Tank Separators In Glycol Dehydrators." http://www.epa.gov/gasstar/documents/ll_flashtanks3.pdf
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Protocol
Emission
Source
Off P
On P
GB
PC
T
s
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
12
Pipeline Venting
and Blowdowns

Y
Y
Y
Y
Y
Y
Y
Y
This protocol does not apply to emergency blowdown
situations.
1.	If company/facility has ownership or operatorship of the
compressor downstream from the point of pipeline
venting or blowdown, use inline compression to maximum
engineering potential. Companies should compare the
amount of gas, on a C02 equivalent basis, that will be
vented during a pipeline blowdown with the C02
emissions from the use of the fuel during inline
compression and any breakeven or higher volume of gas
should be recovered.
2.	If (1) does not apply or maximum engineering potential of
inline compression is reached, when economical, use
portable compression. Companies should compare the
cost of using a portable compressor with the value of gas
that can be recovered and any breakeven or higher value
of gas should be recovered. The value of gas should be
evaluated using a 12-month average wellhead price as
published in EIA6.
13
Pipeline
Inspection and
Repair
(including low
pressure
distribution and
gathering lines
and high
pressure
pipelines)

Y
Y
Y
Y
Y


Y
This protocol applies to each leak found in the survey which is
greater than or equal to 60 grams per hourl of natural gas.
1. Conduct comprehensive leak detection annually, retain
leak records, and perform economical leak repair.
6 U.S. EIA. U.S. Natural Gas Wellhead Price. Available online: http://www.eia.gov/dnav/ng/hist/n9190us3m.htm
15

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U&i	Mays, 2014	NaturalGasA
EPA POLLUTION PREVENTER '
Protocol
Emission
Source
Off P
On P
GB
PC
T
s
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
14
Pressure Relief
Valves - System
Upsets
Y
Y
Y
Y
Y
Y
Y
Y
Y
1. Install rupture disks on all gas pressure relief valves that
release to the atmosphere, unless the PRV is in a closed
system connected to a flare header.
15
Reciprocating
Compressors Rod
Packing
Y
Y
Y
Y
Y
Y
Y
Y
Y
1.	For facility with existing gas capture system or gas capture
system being installed for another protocol, route all vents
to gas capture system for beneficial use. Beneficial use
does not include flaring.
2.	If (1) does not apply, for compressors with backup,
perform economical rod packing replacement.
3.	If (1) does not apply, for compressors without backup,
perform economical rod packing replacement at first
planned maintenance shutdown immediately after period
when rod packing replacement is economical.
4.	If (1) does not apply, do the following for existing flare
connection/header or flare being installed for another
protocol:
a.	on or adjacent to the well pad where the
reciprocating compressor is located for onshore
production segment;
b.	at the gathering and boosting station for gathering
and boosting segment;
c.	within or adjacent to facility boundaries for all other
applicable segments; route all rod packing vents to
flare.
16

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^DST«\
U&i	Mays, 2014	NaturalGasA
EPA POLLUTION PREVENTER '
Protocol
Emission
Source
Off P
On P
GB
PC
T
s
LNGS
LNG
l&E
D
Summary of Proposed Gas STAR "Gold" Protocols
16
Vessel
Blowdowns
Y
Y
Y
Y
Y
Y
Y
Y
Y
1.	For facility with existing gas capture system or gas capture
system being installed for another protocol, route non-
emergency blowdown gas to gas capture system for
beneficial use. Beneficial use does not include flaring.
2.	If (1) does not apply, route non-emergency blowdown gas
to low pressure gas system, if available, to maximum
engineering potential.
3.	When maximum engineering potential is reached, for
existing flare connection/header or flare being installed
for another protocol:
a.	on or adjacent to the well pad where the vessel is
located for onshore production segment;
b.	at the gathering and boosting station for gathering
and boosting segment;
c.	within or adjacent to facility boundaries for all other
applicable segments;
route remaining non-emergency blowdown gas to flare.
17
Cast iron
Distribution








Y
1. Replace, line, and/or otherwise seal 10% of existing cast
iron and unprotected steel pipeline per year. Existing cast

Pipeline and
Unprotected
Steel Pipeline









iron and unprotected steel pipeline is the total miles at
time of joining the Gold program.










2.	If replacing 400 feet or more of cast iron or unprotected
steel pipeline, conduct a pressure drop survey, as
described in the technical background document, to
measure leakage before the cast iron or unprotected steel
pipeline is abandoned.
3.	Perform a leak survey annually.
17

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