1
MEMORANDUM
SUBJECT:
Meeting
Summary
for
the
March
29,
2006
Meeting
Between
the
US
Environmental
Protection
Agency
(
EPA)
and
Jeff
Adams
with
BP
to
Discuss
a
Design
Criteria
Option
for
Oil
and
Natural
Gas
Production
Area
Source
Glycol
Dehydrators
FROM:
Greg
Nizich
U.
S.
EPA.

TO:
Air
and
Radiation
Docket
Docket
No.
EPA­
HQ­
OAR­
2004­
0238
DATE:
April
12,
2006
I
met
with
Jeff
Adams
of
BP
on
March
29,
2006
to
discuss
a
summary
document
from
EPA
(
Docket
ID
No.
EPA­
HQ­
OAR­
2004­
0238­
0048)
outlining
a
list
of
design
criteria
that
area
sources
with
glycol
dehydrators
might
be
able
to
use
at
oil
and
natural
gas
production
sites.

The
following
topics
were
discussed:

1.
The
proposed
annual
reporting
frequency
for
area
sources.
2.
What
obligation
synthetic
minor
sources
currently
controlling
emissions
by
80%
have
to
comply
with
the
area
source
rule.
(
Answer
 
an
overall
hazardous
air
pollutant
reduction
of
95%
or
benzene
emissions
below
1
ton/
year
would
be
required.).
3.
Problems
associated
with
data
recovery
at
unmanned
sites.
BP's
experience
with
remote
site
monitoring
equipment
is
that
the
systems
are
not
always
reliable
and
require
frequent
checking
by
company
personnel.
4.
Mr.
Adams
suggested
that
condenser
outlet­
temperature
monitoring
be
added
to
the
list
of
design
criteria
to
be
recorded
during
maintenance
staff
site
visits.
5.
Consideration
of
a
short
duration
trial
period
(
e.
g.
30
days)
during
which
condenser
outlet
temperature
would
be
monitored
as
a
way
to
verify
correct
installation
and
function
of
a
condenser
system.
This
period
would
then
be
followed
by
manual
readings
by
staff
at
a
predetermined
interval.
6.
Mr.
Adams
said
some
additional
work
had
been
done
through
the
American
Petroleum
Institute
on
the
risk
screening
approach
that
utilized
real
meteorological
data.
He
said
they
would
send
the
EPA
the
results
when
it
was
completed.
Mr.
Nizich
stated
that
EPA
had
not
proceeded
any
further
with
the
risk
screening
approach.
