Date:	July 21, 2016

To:	Brenda Shine and Jonathan Witt, EPA/OAQPS/SPPD

From:	Jeff Coburn

Subject:	Meeting Record for June 2, 2016 meeting between Representatives
of API and Representatives of OAQPS (U.S. EPA)



On June 2, 2016, representatives of the U.S. Environmental Protection
Agency (EPA) and their contractor (RTI International) participated in a
meeting with representatives of the American Petroleum Institute (API).
The names and affiliations of the participants are included in
Attachment 1. The purpose of the meeting was to discuss the existing
source oil and gas information collection request (ICR) and also to
discuss the recently promulgated new source performance standards (NSPS)
for oil and gas facilities (40 CFR part 60 supbart OOOOa) as well as the
Control Techniques Guidelines (CTG) for the oil and gas industry. This
memorandum summarizes only the first half of the meeting, which focused
on the oil and gas ICR. The following topics were discussed.

Mailing List. API representatives expressed concern on how we could
develop accurate mailing lists for respondents to the ICR.  They also
indicated that if we could make sure the mailing lists were accurate,
the 75% response rate assumption could be increased and fewer Part 2
surveys could be mailed out. They suggested an approach where EPA could
conduct an initial mailout to identify responders prior to sending out
the Part 2 surveys.

Schedule. API representatives expressed concern over the deadlines for
survey mailout and responses for both Parts 1 and 2 surveys. They
indicated that neither the 30 day period for submittal of Part 1 nor the
120 day period for submittal of Part 2 were realistic, given the amount
of information that is being requested and the burden of responding,
particularly for respondents that have large numbers of facilities.

Part 1 and Part 2 Questionnaires. API representatives questioned the
need for Part 1, which is a complete survey, given the statistical
sampling approach in Part 2. They also provided the following specific
comments on certain data elements in the Part 1 and Part 2
questionnaires:

API representatives noted that some data elements, such as distance to
gathering lines, were difficult to determine and may not provide the
information the EPA needs (e.g., there may be right-of-way issues to the
“nearest” gathering line). Similar issues pertain to determining
distance from field office. They suggested that these questions may be
more appropriate for Part 2, but the questions need to be clear, so EPA
gets the correct information. 

API representatives also expressed concern over the requirement to
provide information on plugged and abandoned (P&A) wells.  They
explained that the ownership of the land associated with a particular
P&A well could have undergone multiple changes since the time the well
stopped producing and that it can be difficult to track down the precise
location of the well.

API representatives suggested that the EPA could limit the Part 2 survey
by excluding “stripper wells” (wells with production less than 15
barrels of oil equivalent). This could eliminate a large number of wells
while still covering well over 90 percent of the nationwide production.

API representatives questioned the necessity of the draft sampling and
analysis requirements for separators discharging to atmospheric tanks
and asked the EPA to consider more flexible approaches to collecting
data on flashing emissions. They noted that labs in California were
familiar with the “CARB method” required in the draft ICR, but that
labs in other states were not familiar with the method, so they might
not be able to do the analysis and/or the costs would be significantly
higher. API suggested that the EPA include GPA standard methods as
acceptable alternatives to the CARB method.

API representatives expressed concerned that the EPA did not specify
exactly how some data elements would be used in future rulemakings and
pointed to the draft questions on pneumatic devices as an example.
According to API representatives, replacement of high-bleed controllers
with low-bleed controllers is the basic control option, so collecting
detailed information on individual devices was not necessary. The EPA
suggested that more detail is needed to understand the various types of
pneumatic devices and their emission potentials, including how to
identify malfunctioning controllers.  

API representatives also wanted to understand how EPA would consider
useful life of equipment in these future rulemakings and noted that some
additional questions may be needed to assess useful life equipment. 

API representatives noted that companies are constantly acquiring and
divesting wells. They recommended that the EPA specify the date of
ownership for which information is to be provided, so it is clear who
needs to report for wells that may have recently changed ownership.



Attachment 1

Participants in June 2, 2016 EPA/API Meeting

API Representatives

Shankar Ananthakrishna, Chevron

Adam Berig, Encana

Grover Campbell, Devon

Lisa Campbell, ERM

Paul Doucette, GE Oil

Denise Grubert, ERM

Greg Johnston, Chesapeake

Tom Monahan, XTO

Brad Morello, Shell

Venessa Ryan, Chevron

Matt Todd, API

John Wagner, API

Andy Woerner, ERM

Jenny Yang, ConocoPhillips

Angela Zivkovich, Anadarko

U.S. EPA Representatives

David Cozzie

Amy Hambrick

Jodi Howard

Penny Lassiter

Bruce Moore

Brenda Shine

Lisa Thompson

Peter Tsirigotis

Jonathan Witt

RTI International (EPA Contractor)

Jeff Coburn

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