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 9, 2014, Meeting with the Gas
Processors Association (GPA) 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 GPA requested this meeting with the EPA to discuss the comments GPA
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

Gas Processors Association

Jeff Applekamp, GPA

Jeff Adams, BP

Laura Higgins, DCP Midstream

Mary Beth Whitfield, Williams Companies

Tom Bach, Kinder Morgan

Doug Jordan, Southwestern Energy

Grover Campbell, Devon Energy

Jim McCarthy, consultant

EC/R Incorporated

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

Definition of “removed from service” under §60.5430

Applicability status of storage vessels removed from service under
§60.5365

Sufficient time for well completions to come into compliance under
§60.5395(d)(1)(i)

Clarification of requirements for storage vessels returned to service

Clarification of leak free requirement for enclosed combustion devices
under §§60.5413(e)(7) and 60.5412(d)(1)(i)

Compliance requirements for reciprocating compressors under
§§60.5385(a)(3), 60.5410(c)(1) and 60.5415(c)(4)

Applicability of cover and closed vent requirements to reciprocating
compressors under §60.5416(a) and (b)

Definition of “responsible official” under §60.5430

Consistency between the pneumatic controller affected facility
definition in §60.5365(d) and the requirements of §60.5390

Use of electronic spark ignition systems for combustion control 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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