
1
MEMORANDUM
SUBJECT:
Meeting
Minutes
for
the
June
28,
2005
Meeting
Between
the
US
Environmental
Protection
Agency
(
EPA)
and
the
Office
of
Management
and
Budget
(
OMB)
to
Discuss
the
Draft
Oil
and
Natural
Gas
Production
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
Proposal
FROM:
Greg
Nizich
U.
S.
EPA.

TO:
Air
and
Radiation
Docket
Docket
No.
OAR­
2004­
0238
DATE:
June
29,
2005
The
EPA
met
with
OMB
on
June
28,
2005
to
discuss
the
Oil
and
Natural
Gas
Production
(
ONGP)
NESHAP
area
source
proposal
currently
under
review
at
OMB.
The
following
is
a
list
of
meeting
participants:

Greg
Nizich,
EPA
Wendy
Blake,
EPA
K.
C.
Hustvedt,
EPA
Art
Fraas,
OMB
Penny
Lassiter,
EPA
Bill
Nickerson,
EPA
Amy
Branning,
EPA
Edmond
Toy,
OMB
The
following
topics
were
discussed:

1.
Characterizing
Option
1
as
urban
plus
rural
counties
and
Option
2
as
urban
counties
only.
2.
Clarifying
that
the
controls
are
based
on
generally
available
control
technology
and
citing
the
appropriate
Clean
Air
Act
section
(
112(
d)(
5)).
3.
Clarifying
that
census
data
means
decennial
census
data.
4.
Changes
from
the
1998
proposed
rule
to
the
startup,
shutdown
and
malfunction
documentation
and
reporting
requirements.
5.
The
cost
evaluation
for
the
natural
gas
throughput
and
benzene
cutoffs
