Date:	July 14, 2016

To:	Brenda Shine, EPA/OAQPS/SPPD

From:	Jeff Coburn

Subject:	Meeting Record for July 14, 2016 meeting between
Representatives of API and Representatives of OAQPS (U.S. EPA)



On July 14, 2016, representatives of the U.S. Environmental Protection
Agency (EPA) and their contractor (RTI International) participated in a
conference call 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) as it pertains
to the oil and gas production facilities. The following topics were
discussed.

Comment Period. API representatives noted that they had submitted a
request for a 60-day comment period extension and asked if EPA was
considering extending the comment period.  EPA representatives stated
that they did not expect to extend the public comment period, but noted
that there would be a 30-day comment period during the OMB review
period, which will occur after revisions are made to the ICR based on
the comments received during the initial 60-day public comment period.

Pre-Survey Process. API representatives stated the importance of getting
the ICR to the right individuals, particularly given the proposed
schedule of the ICR. They requested that EPA allow facilities to provide
appropriate contact information through an initial mailer or other
mechanism. EPA representatives stated that they plan to provide web
access to the facility list and allow operators to update or correct any
information during the OMB review period.

Statistical Approach for Part 2. API representatives noted that the EPA
provided two different options for the statistical sampling approach:
one based on gas-to-oil ratio (GOR) and one by groupings of basins. API
representatives generally supported the GOR groupings but suggested that
an additional grouping be provided for “stripper wells.” Stripper
wells, according to the API representative, have production rates less
than 15 barrels of oil equivalents/day, which is about 90,000 scf/d of
gas production for gas wells. According to API representatives, these
small wells have similar number and types of equipment, so they should
be grouped together. They further suggested changing the acceptable
margin of error to 15% for three of the GOR groups that are expected to
have small variability. According to API representatives, dry gas wells,
coalbed methane (CBM) wells, and stripper wells have limited variability
and that a higher error margin would be appropriate to allow reduced
number of respondents for these GOR groups. EPA representatives asked if
they had data to support this lower variability. API representatives
noted that this supposition is based on experience with the typical
equipment used on these types of wells.

Part 1 Questionnaire. API representatives stated that some of the
information requested in the Part 1 questionnaire were difficult to
collect or estimate (e.g., distance to nearest gas gathering line,
electricity availability, and distance to field office). API suggested
that this information be collected only in Part 2 and that the EPA could
add a separate “basin-level” section in Part 1 that could collect
this information at the basin level (i.e., Is electrification from the
grid available in the basin? Is there gas infrastructure in the basin?).
API representatives also noted that EPA should clarify that distance
from field offices be based on driving distance rather than GIS mapping
(or “as the crow flies”) distance.

Response Timing: API representatives noted that the time provided to
respond to the survey was not adequate and recommended that EPA provide
more time for operators to collect and provide this data to ensure EPA
gets the correct information. 

Follow-up Meeting: API representatives suggested that a follow-up
meeting be scheduled, perhaps after the end of the comment period once
EPA has had a chance to process some of the public comments. They also
noted that they would like to discuss how the facility counts were
developed as they did not get similar results through their queries
using DI Desktop. EPA representatives noted that these types of meetings
were helpful and were open to scheduling a follow-up meeting in August. 



Attachment 1

Participants in July 14, 2016 EPA/API Conference Call

API Representatives

Grover Campbell, Devon

Lisa Campbell, ERM

Denise Grubert, ERM

Marcus Koblitz, API

Tom Monahan, XTO

Matt Todd, API

Andy Woerner, ERM

Angela Zivkovich, Anadarko

U.S. EPA Representatives

Jameel Alsalam

Angie Carey

Amy Hambrick

Jodi Howard

Penny Lassiter

Brenda Shine

Lisa Thompson

Jonathan Witt

RTI International (EPA Contractor)

Jeff Coburn

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