                                                                               
MEMORANDUM   


TO:		Charlene Spells, EPA/OAQPS/SPPD/FIG

FROM:	David Hendricks, EC/R, Inc.

DATE:	November 5, 2015

SUBJECT:	Summary of the November 3, 2015, Meeting with Noble Energy and the U.S. Environmental Protection Agency 
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I.	INTRODUCTION

Noble Energy Inc. (Noble) 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), draft CTG (80 FR 56577), and proposed Source Determination Rule (80 FR 56579).

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency
Carey Bylin
David Cozzie
Mark DeFigueiredo
Amy Hambrick
Jodi Howard
Bruce Moore
Ravi Srivastava
Charlene Spells
Lisa Thompson
Cheryl Vetter
Suzie Waltzer (by phone)
Matthew Witosky

Noble Energy
Kate Faye
Brian Lockard
Brian Taylor

Beatty and Wosniak
Jim Martin

EC/R Incorporated
David Hendricks (by phone)


III.	SUMMARY OF DISCUSSION

Bruce Moore opened the meeting and explained to the attendees that since 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.

Source Determination Rule
 Noble requested information on the "daisy chain" aggregation concept, and EPA explained how facilities located in close proximity to one another may be aggregated for certain permitting purposes.

NSPS Proposal
 Compliance Date
 Noble expressed concern that the effective date of the proposed rule did not allow enough time for facilities to come into compliance.
 Creating the tracking programs that will be required by the proposed rule will take more time than allowed.
 Gave example of the work they did to develop a tracking system to comply with Colorado's Regulation 7, which took 6 months to develop and an additional 2 months to test. Ten additional people were hired for this effort. In the end, it took nearly a year to fully implement.
 If Noble has to redesign their system for the NSPS, then all the previous work may be lost, which doesn't make sense since the end result of the Colorado rule and the NSPS is the same.
 Suppliers had trouble keeping up with just Noble's demand for OGI cameras (they purchased 16 in addition to the two they already had).
 If the final NSPS requires redesign or re-engineering of equipment, such as may be required for storage vessels, then a 2-month compliance period will not be adequate.
                  
 Fugitive Emissions Monitoring Program
 Noble's voluntary efforts to date, along with their involvement in the development of Colorado Regulation 7, have provided the experience to determine what is needed to comply with a monitoring program. 

 Permitting issues related to regulating methane
 Regulating methane in the NSPS should not trigger PSD or Title V because significance level for these actions are defined in terms of aggregate GHGs, not methane. This issue is addressed in the preamble to subpart TTTT, pp. 608-612.
 Industry would like explicit language in the rule stating that regulation of methane does not trigger NSPS or Title V.
            
 Next Gen Compliance Provisions
 Electronic reporting system (ERT) is source specific, which does not easily integrate with the area reporting allowed in the proposed NSPS.
 ERT requires registration of each facility, which would require registration of each and every wellsite. This would be extremely burdensome.
            
 Oil Well Completions
 Expressed support for the 300 GOR threshold.
 API will provide additional comments on the low pressure well definition (did not specify what issues they had)
 Will the amendments related to combustion control device testing be applied retroactively to devices that have already passed testing under the current requirements?
 The proposed NSPS specifies that 95 percent control is measured on a mass basis. API recommends changing this to a volume basis so that flow rate does not have to be measured.
            
 Pneumatic Pumps
 API will address technical infeasibility of controlling small chemical injection pumps in their comments.
 Some pumps operate only a few strokes per hour and do not generate enough emission flow pressure to get the emissions to a control device.
 Would like an exemption for small pumps.
 Would like an exemption for transfer pumps.
 Pointed out that cost effectiveness was determined using a flow rate of 2 cfh, but pneumatic controllers are allowed to emit 6 cfh. This appeared incongruous.
 Expressed concern about the situation where the existing onsite control device was not originally installed in response to subpart OOOO or OOOOa and may not be permitted. The proposed rule would require pneumatic pumps at this site to be controlled because of the existing control device. Would that control device now be subject to the 95 percent control requirements in subpart OOOOa and associated recordkeeping, reporting, and monitoring? Would the owner be allowed to remove the control device in the future if no longer needed for its original purpose?
            
 Controls for Storage Vessels and Pumps
 Rather than having separate fugitive monitoring requirements as specified in the closed vent system requirements, the proposed fugitive emissions monitoring provisions should apply instead.
 Reiterated their concern about using propene rather than propane for control device testing.
 In another situation related to using existing control devices for controlling emissions from pneumatic pumps, API expressed concern about a situation where the existing control device is required under subpart OOOO or OOOOa for controlling storage vessel emissions. The rule allows the control device to be removed if the storage vessel emissions remain below 4 tpy. Could the control device still be removed if it is also controlling emissions from pneumatic pumps?
            
 Fugitive Emissions Monitoring Program
 Expressed significant concern about the level of detail required in the monitoring plan. Recordkeeping and reporting is too detailed and is unnecessary. For example, a plot plan and monitoring path is not necessary for a well site where there are only a few pieces of equipment on site.
 Requested that there be no change in monitoring frequency based on monitoring results. Prefer annual monitoring.
 If a facility is subject to enforceable state requirements, the facility should be exempt from the NSPS requirements. No equivalency determination should be required. Recommended that a facility would not be an affected facility is enforceable state regulations apply.
 Recommended that applicability for a well site require that additional equipment other than just the wellhead be present.
 Recommended an applicability threshold based on number of components, and an offramp if the number of components is reduced below that number.
 Disagreed that fracturing or refracturing a well triggers a modification since the surface equipment does not change.
 Recommended that no time limit be specified for repairs. Many repairs would require the well to be shut in, which could cost over $100,000 to fix a single small leak. Recommended that repairs occur at the next shutdown.
 Recommended soap bubble verification of repairs instead of OGI.
 Questioned why emissions have to be reduced to 500 ppm after repair when the OGI detection level is considered to be 10,000 ppm.
 Recommended that the rule be flexible enough to allow newly developed detection technologies to be used without having to go through an equivalency determination.
 Developing a monitoring plan at the corporate level and the facility level is not necessary.
 Initial monitoring at a well site should occur 30 days after startup of production, not 30 days after completion. 
            
 Comments on the CTG
 No threshold VOC limits are specified for fugitives monitoring or compressors. There are situations where the gas emitted is almost exclusively methane. Recommended that there be a minimum VOC content threshold. This would also apply to natural gas driven operations like pumps and pneumatic controllers.
 Cost of retrofitting storage vessels was not accurately represented. In many situations the tank will have to be replaced.
 The CTG should include the same provisions as in the NSPS to remove controls from storage vessels if emissions remain below 4 tpy.
 Compliance provisions are not consistent with the NSPS.

