MEMORANDUM  SEQ CHAPTER \h \r 1    

TO:		Bruce Moore, EPA/OAQPS/SPPD/FIG

FROM:	David Hendricks, EC/R, Inc.

DATE:	December 19, 2014

SUBJECT:	Summary of the September 25, 2014, Meeting with the American
Petroleum Institute (API) and the U.S. Environmental Protection Agency
to Discuss the Proposed Reconsideration of Additional Provisions of the
Crude Oil and Natural Gas Production, Transmission and Distribution NSPS

I.	INTRODUCTION

The API requested this meeting with the EPA to discuss the comments API
submitted on the proposed amendments to the Crude Oil and Natural Gas
Production, Transmission and Distribution NSPS (40 CFR Part 60, subpart
OOOO).  This meeting summary will be available in the docket for this
rulemaking (Docket ID No. EPA-HQ-OAR-2010-0505).  The proposed rule was
published in the Federal Register on July 17, 2014 (79 FR 41752).  

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

David Cozzie

Bruce Moore

Chris Frantz

Matthew Witosky

API and Member Organizations

Jenny Yang, ConocoPhillips

Matt Todd, API

John Wagner, API

Becky Keogh, BHP Billiton

Grover Campbell, Devon Energy

Jim Cooper, Chesapeake Energy

Manish Singh, Oxy

Jeff Adams, BP

Angela Zivkovich, Anadarko Petroleum

Tom Monahan, XTO

Jason Zapalac, Anadarko Petroleum

Amanda San Miguel, Marathon Oil

Kenyatta Miles, Shell

Jim Sewell, Shell

Shankar Ananthakrishna, Chevron

EC/R Incorporated

David Hendricks (by phone) 

III.	SUMMARY OF DISCUSSION

Bruce Moore opened the meeting by stating that the proposed rule is
currently in the post-proposal period and the EPA can answer clarifying
questions from the group, but cannot provide any responses to comments
on the proposed rules.  

The API discussed each of the comments they submitted to the EPA on the
proposal and further clarified their position. The topics discussed
include the following:

Storage vessel applicability issues related to §60.5365

Clarification of well completion and production related to §60.5375

Clarification of the standards applicable to new, modified and
reconstructed storage vessels related to §60.5395

Exceptions to the equipment leak standards under §60.5401

Clarification of when control devices must be operational under
§§60.5412(d)(3) and 60.5417(h)(1)(i)

Definition of responsible official under §60.5430

Definition of low pressure gas well under §60.5430

Use of LEL meters to determine when to operate a separator

The point at which the production stage begins

Suitability of electronic spark ignition for combustion devices

Miscellaneous technical corrections

The EPA thanked the attendees for providing this information and stated
that they will review the submitted comments to respond to these issues.
 

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

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