
1
MEMORANDUM
SUBJECT:
Meeting
Minutes
for
the
June
2,
2006
Meeting
Between
the
US
Environmental
Protection
Agency
(
EPA)
and
the
American
Petroleum
Institute
to
Discuss
Geographical
Applicability
Criteria
options
for
the
Oil
and
Natural
Gas
Production
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Area
Source
Glycol
Dehydrators
FROM:
Greg
Nizich
U.
S.
EPA.

TO:
Air
and
Radiation
Docket
Docket
No.
EPA­
HQ­
OAR­
2004­
0238
DATE:
June
2,
2006
The
EPA
held
a
conference
call
with
the
American
Petroleum
Institute
(
API)
and
BP
on
June
2,
2006
to
discuss
options
for
geographical
applicability
for
area
source
glycol
dehydrators.
The
following
people
participated
in
the
call:

Greg
Nizich,
EPA
Stephanie
Meadows,
API
KC
Hustvedt,
EPA
Jeff
Adams,
BP
The
following
topics
were
discussed:

1.
EPA
no
longer
considering
risk
in
the
decision
criteria
to
determine
locations
where
emission
controls
should
be
required.
2.
EPA
considering
use
of
Census­
defined
urban
area
boundaries,
plus
an
offset
distance,
as
the
area
where
controls
would
be
required.
An
offset
distance
of
2
miles
(
to
account
for
non­
urban
"
pockets"
in
urban
areas)
was
mentioned
as
a
possible
distance
given
the
size
of
pockets
in
larger
urban
areas.
3.
Establishment
of
an
online
mapping
tool
to
assist
sources
in
determining
their
location
relative
to
urban
area
boundaries.
4.
Notification
requirements
for
area
sources.
5.
Failure
of
monitoring
equipment
such
as
data
recorders
at
remote
locations.
