                                                                               
MEMORANDUM   


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

FROM:	David Hendricks, EC/R, Inc.

DATE:	April 22, 2016

SUBJECT:	Summary of the January 12, 2016, Meeting with Ormat Technologies, Inc. and the U.S. Environmental Protection Agency 
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I.	INTRODUCTION

Ormat Technologies, Inc. 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
Amy Hambrick (by phone)
Charlene Spells (by phone)
Ravi Srivastava (by phone)

Ormat Technologies
Jenny White-Thompson
Josh Nordquist
Amelia Jenkins, Cassidy & Associates

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
 Discussed the development and operation of Organic Rankine Cycle power plant. 
 These are commercial power plants generating electricity from waste heat from compressor stations (CS). 
 The exhaust from CS turbines is directed into the power plant system. This power can be used to power the plant or sent to local grid or used for other purposes.
 Noted that 17 of 19 states recognize this waste heat recovery (renewable energy generation, or REG) within their RPS renewable goals. 
 Expressed that generating power from waste heat will make sites more efficient and also allows for such sites as island systems to become independent on the power grid. 
 Asked if use of their technology could be used as a compliance pathway beyond looking at leaks which is the immediate goal of the rule.
 Stated the energy used could be used to offset some methane emissions.
 REG is an emission free generation, closed loop power generation system that can be used on any waste heat source.
 Stated the currently lower cost of electric generation may be a limiting factor in adoption of the technology at this time.
 Estimated that each mW-hour of usage equals approximately 1 ton of CO2. 
 Hoped that use of the technology could be applied as a credit, not the same as patching a leak; energy produced at a site would offset the emissions from the exhaust at the CS.
