                                                                               
MEMORANDUM   


TO:		Amy Hambrick, EPA/OAQPS/SPPD/FIG

FROM:	David Hendricks, EC/R, Inc.

DATE:	April 18, 2016

SUBJECT:	Summary of the February 9, 2016, Meeting with the Clean Air Task Force, Environmental Defense Fund and Natural Resources Defense Council and the U.S. Environmental Protection Agency 
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I.	INTRODUCTION

Several environmental groups, the Clean Air Task Force, Environmental Defense Fund and Natural Resources Defense Council, requested this meeting with EPA to present an overview of their comments on the September 18, 2015 proposed Oil and Natural Gas Sector NSPS (80 FR 56593) This summary addresses those comments and other concerns regarding this action.

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency
Bruce Moore
Gerri Garwood 
Eric Goehl 
Brenda Shine 
Penny Lassiter
Amy Hambrick
Lisa Thompson
Elizabeth Miller
David Cozzie (by phone)
Alex McPherson (by phone)
Jodi Howard (by phone)
Charlene Spells (by phone)
Susie Waltzer (by phone)

Environmental Groups
Peter Zalzal, Environmental Defense Fund 
Meleah Geertsma, Natural Resources Defense Council
David McCabe, Clean Air Task Force
Briana Mordick, Natural Resources Defense Council 

EC/R Incorporated
David Hendricks (by phone)

III.	SUMMARY OF DISCUSSION

Bruce Moore opened the meeting and explained to the attendees that because the EPA is in the post-proposal phase of the NSPS and CTG, EPA personnel would listen to their comments but cannot respond to any of the issues raised. However, the EPA welcomed the comments. The attendees offered the following comments.

NSPS Proposal
 LDAR
 Asserted that, according to the latest scientific findings, use of LDAR is more cost effective than EPA projections.
 Stated there is a growing consensus that emissions from super emitters are not reflected in the inventory; if added, would increase LDAR cost effectiveness.
 Studies suggest super emitters shift in time/space, it is not necessarily the same 20% of facilities that account for most emissions at any one point in time, the facilities making up that 20% can vary. 
 Stated that there is no predicting what sites will be super emitters. 
 Believed that an average emission factor approach makes the sense most, but this approach needs to incorporate these other sources, like super emitters, which are not reflected in EPA's average. For example, the Fort Worth study showed that 50% of the emissions came from tanks, which were not included in EPA's average facility.
 Noted a transmission source study that found 23% of emissions were attributable to unexplained events.
 Stated LDAR should be comprehensive and along 2 dimensions in terms of facilities that are covered and components at those facilities. Believed EPA's proposal does a good job, just needs a couple of improvements.
 Regarding facility in the gathering and storage (G&S) segment, noted that a subset of facilities have dehydrators without compressors or storage tanks that are associated with significant emissions. Believed the rule should include coverage of such G&S facilities.
 Believed the definition of fugitive emission component captures a lot and should be finalized.
 Regarding intermittent pneumatic controllers, noted that it can be difficult to use IR cameras but intermittent controllers can malfunction and bleed continuously, as found in the Fort Worth study. Therefore, intermittent pneumatic controllers should be included in the definition.
 Expressed that average facility emissions are bigger than what EPA has predicted, so more frequent quarterly monitoring would be more cost effect. Noted a State of Colorado rulemaking in which environmental groups showed how carbon limits data showed cost effectiveness did not change over the years.
 Expressed concern that incentives created by a setback program creates an incentive to not find leaks. 
 Stated that AVO has value but noted that quite a few leaks are hard to locate unless a camera is used. 
 Believed that OGI is superior to M21 because, while M21 may find leak in general, it cannot pinpoint its location and allow for a repair. 
            
 LDAR Approach
 Expressed their support for allowance of innovation pathways.
 Pointed to Colorado's Rule 7 tiered approach and believed that a tiered approach is most closely tied to the data and that a quarterly approach also has a simplicity.
 Stated that a component approach could be more stringent but that it would also be more arbitrary.
 Pointed to the BLM as having a setback approach that seems to be more stringent than EPA's approach and believed this could be problematic.
 Expressed that it would be inappropriate to continue to exempt low VOC components at gas processing plants from LDAR requirements.
            
 15 BOE 
 Concerned that those sites operated at less than 15 bpd can still be high emitters according to their data (shown in slide). Asserted that many of the wells with the highest emissions fall in the less than 5 bpd category. Thus, these well sites should not be exempted as they are not low emitting and should be surveyed.
 Noted that the PTE approach would be something they might be more comfortable with. 
 Noted that to their knowledge the 15 BOE approach is not currently being used by any states.
            
 Geographic and logistical concerns
 Asserted that most facilities are not isolated, therefore, cost of travel to conduct LDAR is not an issue. 
 Noted that firms with multiple wells also operate with an economy of scale. 
 Believed that use of OGI allows sites to be checked rapidly. 
 Noted that small wells are owned fairly equally between small and large operators.
            
 LDAR Cost Effectiveness
 Offered a slide presentation of ICF's cost analysis study. 
 Noted that the results ICF's study showed that you will find more leaks if you look more frequently.
 Expressed that 5-year study of monthly LDAR proved to be 75-80% cost effective on payback.
 Expressed the environmental performance checks based on a quarterly vs annual basis showed that quarterly showed a 20-30% greater emission reduction over annual.
 In summary, noted that study showed that LDAR was highly cost effective, with substantial emission reductions.
            
 Modifications.
 Stated that EPA should clarify that well workovers are the same as completions and should be considered modifications.  
 Noted that a workover has the same attributes as a completion with hydraulic fracturing. Same physical change, with subpart W emissions associated with that, and an emission increase, thus fitting within the definition of a modification.
 Asserted that acidizing and perforating and making any physical changes to a well can increase emissions. Thus, these events should also meet the statutory definition of a modification.
            
 Equipment Issues
 Expressed that, in general, supported approach for pneumatic pumps/pneumatic compressors, although for pneumatic pumps suggested the rule be extended to say that you must capture any gas that you can and route emissions to a tank with a VRU in place. 
 Suggested EPA clarify that if there is a way to route to a process via VRU or a compression option or a fuel option for reciprocating compressors, then that would be the preferred onsite requirement, with option 2 being routing to a control device, and option 3 being to minimize emissions. 
 Supported the EPA approach taken for pumps; although pumps were not their highest priority, they supported venting to an existing control device. Stated that, based on their knowledge, there are a lot of sites with control devices (because of subpart OOOO control of storage vessels). 
 Inquired about comments received regarding pumps with EPA noting that some commenters requested that portable/occasional pumps have a requirement for applicability cutoffs (e.g., based on hours of operation). Asserted that, to their knowledge, there are no metering devices currently on the market available for this.
 In response to EPA question regarding any analyses to indicate that control of pumps is cost effective, noted they assume costs would be low because of the availability of control devices onsite (information supports that a lot of sites have onsite control). Supported use of VRU as control.
