Date:	June 29, 2016

To:	Brenda Shine, EPA/OAQPS/SPPD

From:	Leslie Pearce and Jeff Coburn

Subject:	Meeting Record for June 23, 2016 meeting between
Representatives of GPA Midstream Association and Representatives of
OAQPS (U.S. EPA)



On June 23, 2016, representatives of the U.S. Environmental Protection
Agency (EPA) and their contractor (RTI International) participated in a
meeting with representatives of the GPA Midstream Association. 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) as it pertains to the gathering and
boosting and gas processing industry segments. 

GPA Midstream Association discussed a number of issues regarding the
information collection request and asked for guidance from the EPA on
how best to document and submit comments to ensure their concerns are
taken into consideration. These issues included:

Part 1 - Operator Survey for Onshore Natural Gas and Petroleum
Production Facilities:

Requested confirmation that gathering and boosting (G&B) facilities are
not expected to complete the Part 1 survey. They also provided feedback
that the point of transfer between onshore natural gas and oil producers
and gathering and boosting facilities would typically be considered the
meter where the commodity leaves the wellhead and enters gathering
lines. They added that gathering and boosting facilities do not
typically take custody of the commodity, but rather charge fees for
transporting and treating the gas or oil. The EPA confirmed that G&B
facilities are not required to complete the Part 1 survey.

Part 2 - Detailed Facility Survey:

Count of Gathering and Boosting Facilities: They inquired where the
count of G&B facilities was sourced, as they did not think these types
of facilities are all subject to the requirements of the Pipeline
Hazardous Materials and Safety Administration (PHMSA) as listed in the
supporting statement. The EPA noted that some of the count was estimated
based on the number of gathering and boosting compressors as provided by
EPA personnel responsible for the Inventory of U.S. Greenhouse Gas
Emissions (GHG) and Sinks report. EPA inquired whether or not the trade
organization had a complete list of gathering and boosting facilities.
GPA Midstream Association stated that they do not have a comprehensive
list, but stated that some of the larger G&B facilities are subject to
the mandatory GHG Reporting Program requirements for stationary
combustion sources (40 CFR part 98 subpart C) and thus some facility
information could be sourced from there. Additionally, they suggested
querying state databases for permitted and registered facilities as well
as state emission inventory reporting programs for facility contact
information. The noted that the information available from the states
vary and some key states, such as Texas, do not require reporting of G&B
facilities. They also suggested that the EPA’s National Emissions
Inventory (NEI) could be queried for SIC codes 1311 or 1389 to get a
list of G&B facilities included in the inventory. They also suggested
that facilities could participate in a self-reporting exercise and
provide the EPA with facility contacts if solicited to do so. They also
noted that most gathering and boosting facilities are owned and operated
by the same company operating the processing plant, so it may be
possible to survey processing facilities to collect information on the
gathering and boosting facilities associated with (i.e., upstream of)
the processing plant. Finally, they suggested that the EPA delay the
overall schedule for the Part 2 survey until after G&B facilities have
reported to the GHGRP or after EPA conducted a similar Part 1 survey to
identify individual G&B facilities.

Dehydrators: GPA Midstream Association asked why dehydrators were
included in the ICR as they were not mentioned in the list of sources to
be included in the April 2016 webinar. They stated that these sources
are heavily regulated by NESHAP HH/HHH for major and area sources.
Additionally, they statement that SO2 removal units are regulated by
NSPS LLL which got included in the NSPS OOOO. They also stated that the
emission points associated with dehydrators are the flash tank and
regenerator vents and asked why questions were not more pointed with
respect to these emission points. Further, they asked the EPA if they
could submit a GLYCalc™ run or simply the emissions from these sources
rather than the requested process information. The EPA explained that
the process information has been requested so they have the ability to
independently and consistently perform emissions calculations for all
facilities as well as identify gaps in regulatory requirements and
existing programs.

Submitting comments: GPA Midstream Association asked the EPA how the
fraction of sources at a given facility in Table 2 of the supporting
statement were derived. The EPA explained that the numbers of pieces of
equipment in Table 2 were taken from information the EPA’s white
paper, engineering estimates, and comments from other EPA groups. GPA
Midstream Association asked if there was a recommended format or
required level of detail when providing comments on the values in Table
2. The EPA suggested providing the suggested revisions and justification
of how the revised estimates were developed in the submitted comments. 

California Air Resources Board (CARB) Methodology: GPA Midstream
Associated inquired why the CARB Method was specifically chosen for
storage tank testing. The EPA explained that the CARB Method was
selected because it has been used in various consent decree settlements
and it is designed for pressurized tank samples. GPA Midstream
Association stated that the cost estimate in the supporting statement
was too low for facilities outside of California, and labs they
contacted were estimating $2,000 per test. GPA Midstream Association
also stated that the CARB Method was updated in February of 2016 and
requested that the EPA confirm which version of the method should be
used. GPA Midstream Association also suggested that there are several
other ways to perform the same types of sampling including GPA methods
(2186, 2174, 2103, and 2286), modeling using ProMax® to estimate
emissions, and other methods submitted as part of 114 requests to EPA
Region 3. The EPA suggested that GPA Midstream Association include their
preferred test method(s) in their comments, but stated that consistency
in results and the ability to quantitatively analyze the results in a
lab instead of modeling emission results were important. GPA Midstream
Association also added that some separators are not equipped with
sampling ports to pull a pressurized liquid sample and that should be
included in the burden estimate. They also added that some facilities
that are not liquid rich (may depend on the time of year) may not be
able to generate a liquid sample, and this should be taken into
consideration.

Timing Concerns: GPA Midstream Association stated that additional time
should be provided to respond to the ICR as it coincides with numerous
other reporting obligations, and they had concerns about using the
e-GGRT system to collect the Part 2 information in such close proximity
to the GHGRP deadline.

Use of e-GGRT: GPA Midstream Association asked whether sandbox testing
of e-GGRT’s ICR portal would be provided. Additionally, they asked if
an XML schema would be provided as a means to provide submission of the
Part 2 data. Finally, they made a recommendation that facilities should
be able to perform registration for a batch of facilities rather than
the current one-by-one process the GHGRP uses.

Burden Estimate: GPA Midstream Association asked if the statistical
method described in the supporting statement would ensure that a
particular parent company would not be overly burdened with the number
of selected facilities for Part 2. The EPA explained that the purpose of
the utilizing the statistical sampling method is to ensure its
randomized and that they expect varied distribution of selected
facilities, but they would accept comment with recommendations on how to
ensure the distribution of selected facilities is appropriate.

Definitions: GPA Midstream Association recommended that the EPA adopt
the facility definition in part 52 of the CAA rather than what appears
to be a composite definition adopted from various parts of the Act. They
also recommended that the definition for pressure vessel be made
consistent with NSPS OOOO.

Miscellaneous:

GPA Midstream Association stated that the information sheet only
references natural gas driven pneumatic devices, but the pneumatics tab
requests information on air driven devices as well.

GPA Midstream Association suggested that the EPA would benefit from
requesting process flow diagrams.

GPA Midstream Association suggested providing a definition for control
device and suggested that some equipment such as vapor recovery units
are used for control, but are often considered part of the equipment.
Specific to vapor recovery units, they also requested clarification on
whether they should be included on the compressor tab.

GPA Midstream Association suggested that a document be added to the
docket with the values of the picklists in the Excel workbooks. They
also stated that the picklist for the type of feed for storage tanks
should be updated to remove exempted types of feed as detailed in the
Intro tab. They also added that adding an option for an enforceable
permit to the list of questions related to regulatory applicability for
the equipment.

Storage Tanks: GPA Midstream Association requested that a separate tab
be provided for tanks and separators rather than lumping together in one
tab. They added that there are no emissions from separators in the G&B
segment because they are simply process pass through units. They also
requested that a definition of atmospheric tank be provided.

Control Equipment: GPA Midstream Association suggested that there be a
link between the control equipment and the emission points on the
equipment tabs.

Blowdown: GPA Midstream Association inquired as to whether it is the
EPA’s intent to provide the same threshold exemption as the GHGRP.
They also requested clarification as to whether a pressure relief device
opening would be considered a blowdown or venting.



Attachment 1

Participants in June 23 2016, 2016 EPA/GPA Midstream Association Meeting

GPA Midstream Association Representatives

Claudio Galli

Laura Guthrie

Laura Higgins

Jaron Hill

Matt Hite

Gary Jackson

Ryan Perna

Melanie Roberts

Adrienne Sandoval

U.S. EPA Representatives

Angie Carey

Amy Hambrick

Jodi Howard

Brenda Shine

Jonathan Witt

RTI International (EPA Contractor)

Jeff Coburn

Leslie Pearce

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