                                                                               
MEMORANDUM   

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

FROM:	David Hendricks, EC/R, Inc.

DATE:	December 2, 2015

SUBJECT:	Summary of the December 1, 2015, Meeting with Hess Corporation and the U.S. Environmental Protection Agency 
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I.	INTRODUCTION

Hess Corporation (Hess) 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).

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency
Amy Hambrick
Jodi Howard
Alex Macpherson
Bruce Moore
Lisa Thompson
Matthew Witosky

Hess Corporation
Blane Helton
Alan Lindsey
Joel Noyes
Lesley Schaaff
Vicky Sund
Tony Webster

EC/R Incorporated
David Hendricks 


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.

Background on Hess
 Hess is a global company that focuses on exploration and production. Their operations are generally evenly split between domestic and international as well as onshore and offshore. About 80 percent of their production is oil.
 The company's largest assets are in the Bakken, where they operate about 1,200 wells. They have been operating there since 1951. Also operate in Texas.

Infrastructure Challenges in North Dakota
 The infrastructure of most production companies is lagging behind the production expansion in the Bakken. Hess has recently spent over $1.5 billion dollars to upgrade infrastructure.
 Highly reliant on third party mid-stream companies to provide infrastructure.
 Capacities issues related to infrastructure limit gas recovery.
 Long lead times to permit pipelines and obtain the necessary right of ways. One federal permit took several years to obtain.
 North Dakota has instituted guidelines to help manage infrastructure expansion with the intent of reducing flaring.
 Industry developed best practices and recommendations to the state.
 State issued guidance policy for new wells. Before wells can be drilled, must submit a gas capture plan, including input from the mid-stream company receiving the gas showing that they have the necessary capacity. Operators are required to capture 77 percent of gas from wells. This will go up to 80 percent in April 2016, 85 percent in November 2016, 88 percent in November 2018, 91 percent in November 2020, and eventually to 95 percent. If targets are not met, then the state can implement daily fines or even shut in the well.



NSPS Proposal
                  
 Would like to reconcile differences between current North Dakota rules and the proposed NSPS.
 Green Completions
 During Hess's completion process, the flow is typically directed to a separator immediately upon beginning flowback. There is no period of time during completion that they cannot combust the gas from the well.
 North Dakota does not allow any direct venting of gas during the completion process.
 Concerned that the proposed rule appears to exclude the option of flaring during initial flowback.
 Concerned that "technically infeasible" as it refers to directing recovered gas to a pipeline is not clearly delineated.
 Fugitive Emissions Monitoring Program
 Will provide comments on the safety and logistical challenges of conducting surveys in oilfields.
 Concerned that a component count would be necessary in order to calculate the percent leaking components.
