Date:	July 13, 2016

To:	Brenda Shine, EPA/OAQPS/SPPD

From:	Leslie Pearce and Jeff Coburn

Subject:	DRAFT Meeting Record for July 12, 2016 meeting between
Representatives of Dominion Energy and Representatives of OAQPS (U.S.
EPA)



On July 12, 2016, representatives of the U.S. Environmental Protection
Agency (EPA) and their contractor (RTI International) participated in a
meeting with representatives of Dominion Energy (Dominion). 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 Dominion’s
assets. 

	Dominion provided an overview of their operations stating that they
have 24,000 MW of power generation, 12,000 miles of transmission
pipelines, natural gas distribution operations in Ohio and West
Virginia, 930 BScf storage fields in Ohio and Pennsylvania, one
liquified natural gas import/export facility, five natural gas liquid
facilities, gathering and boosting facilities and a small amount of
production. Dominion will therefore be responding to the ICR for nearly
all applicable industry segments.

	Dominion inquired whether additional time would be provided to submit
comments. The EPA explained that it would be unlikely that additional
time would be provided.

	Dominion provided comments on several issues including:

Underground Storage:

On the ‘Equipment Leaks’ tab of the Part 2 detailed facility survey,
Dominion recommended that the component types listed should be
consistent with those in 40 CFR part 98 subpart W for the underground
storage industry segment if the intent was to collect fugitive leaks for
this segment. The EPA confirmed that the intent was to collect data for
equipment leaks from the underground storage segment and recommended
that Dominion include this in their submission of comments on the ICR.

Dominion requested confirmation that if a facility is subject to 40 CFR
part 98 subpart W and there are elements in the survey that overlap with
those reporting requirements, facilities will not have to complete those
portions of the surveys. The EPA confirmed that data reported to 40 CFR
part 98 subpart W would not have to be reported again in the ICR
surveys.

Dominion requested clarification regarding the applicability of the
‘Well Sites’ tab in the Part 2 detailed facility survey stating that
underground storage facilities have well site assets and applicable
data. The EPA stated that this tab is only applicable to the onshore
petroleum and natural gas production segment. Dominion suggested that
this tab be ‘blacked out’ if a segment other than onshore petroleum
and natural gas production is selected on the ‘Facility’ tab. 

In discussions about the underground storage segment, the EPA stated
that it also intended to collect information for blowdowns from this
segment. Dominion suggested that the EPA clarify this intent in the
instructions or on the ‘Blowdowns’ tab.

Tanks/Separators

Dominion requested clarification between the terms tanks and separators
and whether the 10 bbl/day exemption that is present in 40 CFR part 98
subpart W applies to the information being collected in this ICR. The
EPA stated that it considers separators to typically precede tanks and
that tanks are the first atmospheric point. The EPA stated that there is
no threshold exemption for the ICR.

Dominion also inquired about the testing requirement for separators and
stated that the requirement will be burdensome for downstream operations
(i.e., transmission compression and underground storage facilities),
especially in consideration of the fact that the feed material at such
facilities is pipeline quality natural gas and thus the expected
emissions would not exhibit the same type of variability as upstream
emissions. Dominion requested that the EPA provide some type of burden
reduction for downstream segments relative to the testing requirements
such as an alternative means of measuring/estimating emissions or
requiring testing of only a percentage of the overall population of
facilities selected for the Part 2 survey. The EPA stated that Dominion
should include their suggestion in their submission of comments on the
ICR and that it would be important for any burden reduction to be
replicable, consistent, randomized and representative of the respective
segment.

Coverage of Facilities

Dominion asked that the EPA confirm that the Part 1 operator survey is
only applicable to the onshore petroleum and natural gas production
segment and the Part 2 detailed facility survey is only applicable to a
statistically selected subset of facilities. Dominion also inquired how
address lists for facilities will be compiled. The EPA confirmed
Dominion’s understanding of the applicability of the surveys and
stated that it plans to post the address list for each industry segment
to a website during the Office of Management and Budget comment period,
providing stakeholders with the opportunity to review and provide edits
to the address list.

Pneumatics

Dominion recommended that the terms for pneumatics be made consistent
with those in 40 CFR part 98 subpart W. They also stated that some of
the terms in the pneumatics tab were confusing because they mixed
function and operation of the devices. The EPA stated that the emission
factor categories used in 40 CFR part 98 subpart W were overly broad and
that the intent of the ICR is to gather more granular information to
refine this emission factor set. Dominion then suggested that
definitions of the types of pneumatics be provided.

Instructions

Dominion requested clarification regarding what aspects of the survey
required facilities to collect additional new information and what
portions of the survey are to be completed with best available
information. The EPA stated that the survey included statements where it
is expected that facilities obtain and report new data (i.e., separator
testing, equipment leak counts) and the remainder of the survey should
be completed with best available information. The EPA stated that
additional clarification will be added in the ‘Instructions’ tab to
make the intent clear.

Other

Dominion stated that the question in the Part 1 operator survey
regarding whether facilities are manned or unmanned should be considered
confidential business information because of security concerns.

Dominion also suggested that the question of whether the facility has
electricity be re-phrased to ask whether a site has sufficient
electricity to supply ancillary systems.



Attachment 1

Participants in July 12 2016, 2016 Dominion Energy Meeting

Dominion Energy Representatives

Lisa Beal

Alice Prior

Anand Yegnan

U.S. EPA Representatives

Angie Carey

Amy Hambrick

Jodi Howard

Penny Lassiter

Brenda Shine

Jonathan Witt

RTI International (EPA Contractor)

Jeff Coburn

Leslie Pearce

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