June 2022
©
DIVERSIFIED
energy
EPA Natural Gas STAR & Methane Challenge
Implementation Plan
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NaturalGasfi
EPA POLLUTION PREVENTER '
DIVERSIFIED ENERGY COMPANY
IMPLEMENTATION PLAN V.l
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Table of Contents
1. Corporate Overview and Commitments 3
1.1 Methane Challenge Commitment 3
1.2 Methane Emission Reduction 4
1.3 Baseline Year 5
2. Onshore Production 6
2.1 Milestones/Timeframes for Methane Reductions 6
3. Boosting & Gathering 6
3.1 Milestones/Timeframes for Methane Reductions 7
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1. Corporate Overview and Commitments
Diversified Energy Company ("Diversified") is an independent owner and operator of oil and natural gas
wells that cover 8-separate EPA reporting Sub-Basins. Diversified operates these wells in Oklahoma,
Texas, Louisiana, Pennsylvania, Ohio, West Virginia, Kentucky, Tennessee, and Virginia. The Diversified
acquisition model focuses on acquiring existing producing wells that are long-life, and low decline1.
Operations is focused on effectively managing these assets to improve or restore production, optimize
compression, increase efficiencies, and reduce emissions before safely and permanently retiring those
assets at the end of their useful lives.
The Diversified operated asset base is comprised of over 86,000+ conventional and unconventional
natural gas, and oil producing wells and approximately 17,000 miles of natural gas gathering pipelines.
Along the ~17,000 miles of pipelines you will find a system of compressor stations.
1.1 Methane Challenge Commitment
As a part of Diversified's Responsible, Stewardship-Based model2, tackling climate-related exposure is a
key strategic opportunity for Diversified to lower carbon emissions while preserving a critical role in an
ever-evolving energy industry. During 2020, Diversified established a Greenhouse Gas ("GHG")
emissions baseline and set future climate-related goals including benchmarks, and emission reduction
targets. Diversified further refined this baseline in 2021. The Diversified emission reduction plan includes
a holistic, long-term approach to achieve net-zero carbon emissions by 20403.
1 About DEC, as discussed in the 2021 Sustainability Report - Poised to Thrive Through the Energy Transition 2021
Sustainabilitv Report
2 A Responsible, Stewardship-Based Model as discussed in the Capital Markets Day Presentation dated Nov 17, 2021.
Capital Markets Day Presentation
3Emission Reduction plan as outlined in Diversified's Climate Change Policy
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The Natural Gas STAR & Methane Challenge Programs are a flexible, voluntary partnership between the
U.S. Environmental Protection Agency (EPA) and Diversified Energy Company. These voluntary
programs allow the EPA to collaborate with Diversified to promote and track ambitious, transparent
commitments to voluntarily reduce methane emissions beyond regulatory requirements and to
recognize Diversified for their progress. The voluntary agreement, as of today, between the U.S. EPA
and Diversified Energy applies to pneumatic controllers in the Onshore Production segment, and to
pneumatic controllers and reciprocating compressors as part of the Gathering and Boosting Segment.
Additional emission categories can be added in the coming years. Diversified's methane reduction
targets are detailed in the table below.
Table 1. Methane Emission Reduction Targets
Objective
Emission
Category
Start Date
Target Year
Onshore Production
Methane
Emission
Reductions
Pneumatic
Controllers
Nov 1, 2021
2026
Gathering & Boosting
Methane
Emission
Reductions
Pneumatic
Controllers &
Nov 1, 2021
2026
Gathering & Boosting
Methane
Emission
Reductions
Reciprocating
Compressors
Nov 1, 2021
2026
1.2 Methane Emission Reduction
Diversified recognizes that climate change is a complex global issue that requires governments, businesses and
communities working together on appropriate, achievable policies, and we are committed to playing our part in
supporting the goal of responsibly transitioning to a lower carbon world. We are committed to helping the US do
its part in meeting the world's methane emission reduction aspirations of 30% by 2030 as compared with 2020
levels and as set out at the 2021 UN Climate Change Conference (COP26)3. Diversified has defined 2020 as a
baseline year for methane emissions. Diversified will report methane emission reduction progress using
Reporting Year 2020 as a guidepost. Diversified has established a distinct methane reduction target year for its
pneumatic devices as part of its production assets and its pneumatic devices and compressors as part of its
gathering and boosting assets.
3As discussed in Diversified's Climate Change Policy
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1.3 Baseline Year
Diversified has defined the methane emission baseline year as 2020. Using the 2020 methane
emissions as a guidepost and driven to improve the carbon footprint of Diversified's portfolio, the
internally developed Project Fresh initiative commenced in 2021 to refine the precision of emission
measurement and reporting. The primary goal of Project Fresh was to measure emissions from
Diversified's producing infrastructure to more accurately calculate actual GHG emissions.
Diversified placed significant methane emission reduction attention and action in 2021 on pneumatic
devices through the comprehensive Project Fresh initiative. An improved pneumatic device inventory
and collection of related actuation activity data enhanced the emissions baseline for this source
category. In addition, Diversified looks to expand on its methane emission reductions by targeting
reciprocating compressors over the coming years.
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2. Onshore Production
Diversified has assessed all methane sources from pneumatic devices and ranks the impact of each
location by total methane emissions. Impact in this context refers to the significance of total methane
emissions per pneumatic device located within the boundaries of "Onshore Production" as defined by
the EPA.
2.1 Milestones/Timeframes for Methane Reductions
1. Onshore Production Pneumatic Controllers - RY 2026
a. Continued aggressive capital investments in emission reduction plans.
b. Install air compression, (instrument air), to eliminate utilization of methane for
pneumatic devices at 150 distinct locations (Onshore & B&G combined) by 2026.
c. Diversified will average ~37 conversions per year between our Central District and
Appalachia Operational footprint.
3. Boosting & Gathering
Diversified has started to evaluate methane sources from pneumatic devices within the EPA Defined
Boosting and Gathering ("B&G") segment. Upon completion of the pneumatic device analysis, Diversified
will rank the impact of each B&G location by total methane emissions. In addition, Diversified has
ongoing methane emissions reduction projects to replace natural gas driven pneumatics with
instrument air driven alternatives. Another area of methane emission reduction opportunity for
Diversified lies with its reciprocating compressors. Rod packing systems emit small amounts of gas
either into an open distance piece to the atmosphere or through an atmospheric vent line connected to
the packing case, or both. Individual cylinder packing vents are normally manifolded together to a single
vent. The piston rod packing is used to create a seal around the piston rod to prevent large amounts of
high-pressure gas leakage from the cylinder. A set of flexible, segmented rings in a packing cup is
pressed against the rod to inhibit emissions down the shaft. These rings oscillate back and forth with
the rod reciprocal movement, sealing against the cup faces to prevent leakage around the rings.
However, some gas slips around the rings with each stroke. This amount increases over time as
packings are further worn out.
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3.1 Milestones/Timeframes for Methane Reductions
1. Gathering & Boosting Pneumatic Controllers
a. Diversified is committed to resurvey all pneumatic devices in-order to update and
verify source- level field data that is used for methane emission calculations by the
end of 2023
b. Continued aggressive capital investments in emission reduction plans.
c. Install air compression, (instrument air), to eliminate utilization of methane for
pneumatic devices at 150 distinct locations (Onshore & B&G combined) by 2026.
d. Diversified will average ~37 conversions per year between our Central District and
Appalachia Operational footprint.
2. Gathering & Boosting Reciprocating Compressors
a. Diversified is committed to have a survey completed by 2024 of compressors that
require a rod packing change
b. Replace rod packing based on survey data as appropriate
c. Achieve methane emissions reductions by 2026
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OMB Control No. 2060-0722
Approval expires 12/31/2024
Methane Challenge Program
Implementation Plan
Partner Name Current As Of (Date)
Diversified Energy Company June 2022
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This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq.
(OMB Control No. 2060-0722). Responses to this collection of information are voluntary 42 USC 7403(g). An
agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless
it displays a currently valid OMB control number. The public reporting and recordkeeping burden for this
collection of information is estimated to be 37 hours per response. Send comments on the Agency's need for this
information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent
burden to the Regulatory Support Division Director, U.S. Environmental Protection Agency (2821T), 1200
Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do
not send the completed form to this address.
EPA Form No. 5900-410
Template last updated: 9 December 2021
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Methane Challenge Program Implementation Plan
Methane Challenge Commitments1 - BMP Commitment Option
Source
Start Date
Achievement Year
Onshore Production
B
Pneumatic Controllers
Nov 1, 2021
2026
Equipment Leaks/Fugitive Emissions (commitment not finalized)
Liquids Unloading (commitment not finalized)
Pneumatic Pumps (commitment not finalized)
~
Fixed Roof, Atmospheric Pressure Hydrocarbon Liquid Storage Tanks
Continuous Improvement Source (TBD)
Continuous Improvement Source (TBD)
Gathering and Boosting
H
Pneumatic Controllers
Nov 1, 2021
2026
Equipment Leaks/Fugitive Emissions (commitment not finalized)
Pneumatic Pumps (commitment not finalized)
~
Fixed Roof, Atmospheric Pressure Hydrocarbon Liquid Storage Tanks
B
Reciprocating Compressors - Rod Packing Vent
Nov 1, 2021
2026
~
Centrifugal Compressors - Venting
Continuous Improvement Source (TBD)
Continuous Improvement Source (TBD)
Natural Gas (NG) Processing
~
Reciprocating Compressors - Rod Packing Vent
~
Centrifugal Compressors - Venting
Continuous Improvement Source (TBD)
Continuous Improvement Source (TBD)
NG Transmission & Underground Storage
~
Reciprocating Compressors - Rod Packing Vent
~
Centrifugal Compressors - Venting
~
Equipment Leaks (Compressor Blowdown and Isolation Valves)
~
Transmission Pipeline Blowdowns between Compressor Stations
(Commitment Rate: ; must be 50% or greater)
~
Pneumatic Controllers
Continuous Improvement Source (TBD)
Continuous Improvement Source (TBD)
NG Distribution
M&R Stations/City Gates (commitment not finalized)
~
Mains - Cast Iron and Unprotected Steel (Commitment Rate: )
~
Services - Cast Iron and Unprotected Steel
~
Distribution Pipeline Blowdowns (Commitment Rate: ; must be
50% or greater)
~
Excavation Damages
~
Renewable Natural Gas
Continuous Improvement Source (TBD)
1 Partners may delete unused rows within the table and may duplicate rows and add relevant details as needed (e.g., a corporate parent
partner that has different commitments for each LDC can duplicate relevant rows to list the commitments for each LDC).
EPA Form No. 5900-410
Template last updated: 9 December 2021
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Methane Challenge Program Implementation Plan
Source
Start Date
Achievement Year
Continuous Improvement Source (TBD)
Methane Challenge Commitments - ONE Future Emissions Intensity Commitment Option
Segment:
Intensity Target:
Target Year:
EPA Form No. 5900-410
Template last updated: 9 December 2021
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Methane Challenge Program Implementation Plan
Milestones/Timeframes for Meeting Commitments
Provide information on steps for achieving commitments such as anticipated rate ofprogress, key milestones, or other
context (e.g., referencing work to be done during the next planned shutdown of a facility).
See Attached implementation plan.
EPA Form No. 5900-410
Template last updated: 9 December 2021
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Methane Challenge Program Implementation Plan
Additional Information/Context (optional)
Use this space, if desired, to provide other information about Program participation, such as plans for expanding Methane
Challenge commitments, how historical actions informed Methane Challenge commitments, or other information on how the
Program will be implemented.
See Attached implementation plan.
EPA Form No. 5900-410
Template last updated: 9 December 2021
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