Date:	August 18, 2016

To:	Brenda Shine, EPA/OAQPS/SPPD

From:	Jeff Coburn and Cassy Becker

Subject:	Meeting Record for August 18, 2016 meeting between
Representatives of ONE Future and Representatives of OAQPS (U.S. EPA)



On August 18, 2016, representatives of the U.S. Environmental Protection
Agency (EPA) and their contractor (RTI International) participated in a
conference call with representatives of Our Nation’s Energy (ONE)
Future. 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) comments
provided to the EPA by ONE Future on August 2, 2016. The following
topics were discussed.

ONE Future Overview. ONE Future representatives provided a brief
overview of the group’s structure and goals.  They explained that ONE
Future consists of eight (8) companies working together with a goal of
reducing methane emissions across the entire natural gas value chain to
one percent or less of total natural gas gross production. ONE Future
representatives noted that production member companies include BHP
Billiton, Southwestern Energy, Apache Corporation, and Hess; Kinder
Morgan and Columbia Pipeline Group represent the transmission sector;
AGL Resources (a division of Southern Gas) and National Grid are
involved in the distribution of natural gas. ONE Future representatives
stated that under the guidance of the Methane Challenge, ONE Future has
been working to meet their one-percent-methane goal by setting targets
for each of the natural gas segments. The representatives explained that
these targets are individualized for each sector based on the cost
effectiveness and efficacy of emission reduction techniques.

Policy Neutral Focus.  ONE Future representatives noted that their ICR
comments were focused on the big-picture issues rather than delving into
the technical aspects. They indicated that one of their primary ICR
comments focused on the idea of policy neutrality. ONE Future
representatives requested that the EPA maintain a neutral and open
minded approach to the development of regulations for existing oil and
gas facilities. They provided several policy tool examples to reduce
methane emissions: voluntary-based options such as the Methane
Challenge, technology-based options similar to NSPS OOOOa,
performance-based options under §111(d) of the Clean Air Act (CAA), and
market-based options including tradable programs. ONE Future
representatives asserted that science should lead policy, not vice
versa, and that scientific communities have come to realize that
emissions reduction is not “one size fits all.” They explained that
ONE Future has developed the best program which is performance-based,
has clear set methane reduction goals, has clear accounting, and
contains appropriate monitoring mechanisms to make sure all standards
are met. EPA representatives indicated that they were open to all
options with regard to methane regulation on existing oil and gas
facilities.

ICR Time Constraints. ONE Future representatives noted that their other
main concern regarding the ICR was timing. They explained that the
current ICR deadlines were not appropriate as the intersected with
greenhouse gas reporting and Title V certification submissions. EPA
representatives stated that this was a common concern among many of the
ICR commenters and that they would relay the concerns expressed by
commenters regarding the timing of response deadlines to EPA management.

	Directed Inspection and Management Practices. ONE Future
representatives provided an overview of leak inspection procedures at
member company Kinder Morgan. They explained that while the company
generally looked at every component of their compressor stations, they
focused their efforts on detecting and repairing leaks from the typical
equipment that provided a majority of their fugitive emissions. ONE
Future representatives stated that most of their fugitive emissions came
from a small number of leaks. EPA representatives questioned that if the
industry knows what equipment accounts for the largest amount of
emissions (for example, isolation valves and blowdown valves for
reciprocating compressors), why was the source not already controlled?
ONE Future representatives responded that controlling leak emissions
from blowdown vent stacks would be a concern from both a safety and a
design aspect, as these vents are the point of not only valve leakage,
but also large volumes of blowdown gas for unit shutdowns and station
emergency shutdown events.  They stated that a control device, such as a
flare, would need to be designed to handle both large and small volumes
of gas from many vent stacks, which has not yet been done effectively.
ONE Future representatives also discussed the Leak Detection and Repair
(LDAR) program at member company Southwestern Energy’s gathering and
boosting facilities, where they have established leak thresholds that
indicate the need for equipment repair.



Attachment 1

Participants in August 18, 2016 EPA/ONE Future Conference Call

ONE Future Representatives

Richard Hyde, Southern Gas Company and ONE Future Coalition

Fiji George, Southwestern Energy

Tom Hutchins, Kinder Morgan

Tom Bach, Kinder Morgan

Sandy Taft, National Grid

Pat Dorsch, National Grid

Terri Lauderdale, AECOM

Matt Harrison, AECOM

Mike Ford, Hess

Ed Mongan, BHP Billiton

U.S. EPA Representatives

Angie Carey

Brenda Shine

Jonathan Witt

Justin Pryor

Carrie Bylin

RTI International (EPA Contractor)

Jeff Coburn

Cassy Becker

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