                                                                               
MEMORANDUM   


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

FROM:	Veronica Hanzel, EC/R, Inc.

DATE:	May 10, 2016

SUBJECT:	Summary of the November 10, 2015, Meeting with the Gas Processors Association (GPA) and the U.S. Environmental Protection Agency 
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I.	INTRODUCTION

The Gas Processors Association (GPA) requested this meeting with EPA to present an overview of their comments on the November 10, 2015 proposed Oil and Natural Gas Sector NSPS (80 FR 56593), draft CTG (80 FR 56577), proposed Source Determination Rule (80 FR 56579), and proposed FIP for EPA's Indian Country Minor NSR program. This summary addresses the first discussion on the first three actions.

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency
Jodi Howard
Amy Hambrick
Bruce Moore
Greg Nizich
Charlene Spells
Lisa Thompson
Matthew Witosky
Chris Stoneman
Jameel Alsalam (by phone)


GPA and Member Organizations
David Oldaker, Enterprise Products
Jaron Hill, Williams
Matt Hite, GPA
Claudio Galli, Enbridge
Melanie Roberts, Targa Resources
Adrienne Sandoval, Tesoro Logistics
Jeff Stovolle, Crestwood

EC/R Incorporated
Veronica Hanzel (by phone)
Joanne O'Loughlin (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.

Tribal New Source Rule
 GPA noted that registration under NSR will disadvantage tribes; specifically that there is no synthetic minor only true minor facilities would likely be affected.
 Noted that all other states have minor source permits and presented a table of their research summarizing nearby states and the oil and natural gas permitting options (see attached, "Comparison of Commonly Used permitting Options for Midstream Sites")
 These permits are typically used for compressor stations and natural gas processing plants and provided federally enforceable limits. GPA also noted concerns on application timeline that could cause different choices to be made.  
 Greg Nizich requested any ideas on ways to incorporate synthetic minor into non-attainment areas.
 GPA asked if there are other FIPs or discussion n place. For Tribal and Federal lands the oil and natural gas is the largest and asked if there are others intending to go after methane emissions.  
 GPA noted that it is hard to tell if true minor sources are excluded from FIP and typically true minors are covered under general permits.
 A comment was made that it is more common to have many small processing plants versus large plants and that EPA should evaluate pipeline and small plant cost
 Comment was made that the 30 day registration timing is a problem due to the many changes made from planning and specification to actual build and wanted to know if using the timing in the FIP until a non-attainment FIP was available as the interim FIP timeline was a big issue. 
 Suggested non-attainment FIP supersede and that EPA avoid side-by-side permit review at the regional level due to timing (not enough staff), and streamline the process as much as possible.
 Wanted to have the FIP handle minor modification at major sources.

NSPS Proposal
 Next Generation Compliance approach
 GPA noted that these approaches are not applicable to smaller, more remote sites.
 EPA requested comment on issues such as 3[rd] party verification. GPA notes it is very different for unmanned locations.
 Electronic reporting will required systems to be updated and robust enough to handle the data input. Systems this size operated by EPA have experienced significant problems before in implementation.
            
 Pneumatic pump
 GPA noted concerns with control cost only being routing to a control device and that there are engineering problems with routing to a control device.
 GPA asked what the "out" is for technical feasibility issues and stated that there could be many unintended consequences.
 On the subject of low usage pumps (i.e., lubrications pumps, slop pumps). Is there a way to address these and differentiate them from other pumps? It would be ridiculous to keep rate meter on these low use pumps, have operation time logged. GPA stated it would be helpful if EPA would provide an emission threshold. 
 GPA asked if control device requirements could match up with requirements for storage vessels or default to the requirements already in effect (i.e., state NSR permit).
 Timing could be an issue in being able to route pumps to a control device.
 GPA stated that control device requirements could be retroactive to OOOO sources and EPA should look at that.
 GPA noted that the rule has some ambiguity with respect to pumps which leave interpretation open to inspections and could cause unintended costs due to different interpretations.
            
 Fugitives Monitoring
 Expressed concern with third party verification. Noted it is very time consuming and expensive.
 The fugitives' definition of modification is problematic. How id modification tied to emissions at the site? For compressor stations, changing capacity does not necessarily increase emissions, in fact, the emissions may be lower. GPA stated that EPA needed to make it clear that something that had changed causing an increase in emissions not based on activity. 
 GPA also question timelines as potentially undoable. 
 GPA reiterated comments on use of photographs, logs, compliance costs. 
 GPA also noted that their comments identified several questions on intent of the requirements, specifically with respect to off-ramps for leaks under control, definition of well site and compressor station, ownership of production equipment.

 CTG Questions
 GPA noted that the requirements seem to copy those of OOOOa for methane and VOC, however is should only be for VOC. 
 GPA questioned whether there should be some minimum percent VOC for the requirements to apply.
 GPA questions why there was no 4 tpy cut-off for storage vessels citing that the storage vessel requirements were significantly different than other requirements making it difficult to compare. 
 GPA asked why the compliance requirements were stricter than the NPS.








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