Date:	August 30, 2016

To:	Brenda Shine, EPA/OAQPS/SPPD

From:	Jeff Coburn and Cassy Becker

Subject:	Meeting Record for August 25, 2016 meeting between
Representatives of GPA Midstream and Representatives of OAQPS (U.S. EPA)



On August 25, 2016, representatives of the U.S. Environmental Protection
Agency (EPA) and their contractor (RTI International) participated in a
meeting with representatives of Gas Processors Association (GPA)
Midstream. The names and affiliations of the participants are included
in Attachment 1. The purpose of the meeting was to discuss the Indian
Country NSR, petitions to NSPS OOOOa, and the existing source oil and
gas information collection request (ICR) comments provided to the EPA by
GPA Midstream on August 2, 2016. With respect to the ICR, the following
topics were discussed.

Midstream Overview. GPA Midstream representatives provided a general
explanation of gathering and boosting operations to further EPA’s
understanding of the sector.  They explained that gathering and boosting
pipelines are not a single, straight pipeline, but rather a network of
pipelines that interconnect and feed into differing networks.  GPA
Midstream also requested that EPA distinguish gathering and boosting as
a separate sector from production in all areas of the ICR.   

ICR Time Constraints. GPA Midstream representatives requested more time
to respond to the ICR.  They noted that not only will the ICR intersect
with greenhouse gas reporting, emissions inventories, and Title V
reporting, but it will also require extensive field time for the
equipment counts and sampling procedures. GPA Midstream representatives
voiced their concerns about the possibility of creating a backlog of
pressurized liquid samples at analysis laboratories, which could delay
ICR responses. Specifically, GPA Midstream requested 240 days to respond
to the ICR which would allow for companies to provide 2016 data. 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.
EPA representatives also stated that the best available information
should be provided, which should provide relief to time constraints. 

Statistical Sampling Procedures and Mailing List. GPA Midstream
representatives proposed using the Greenhouse Gas Reporting Program 2016
Subpart W data to compile a list of gathering and boosting facilities.
EPA representatives explained that this was not an option due to timing
constraints, but that they were open to suggestions regarding the
mailing list composition methodology. GPA Midstream representatives
stated that they will pose the question to members and provide a
response at a later time.

Pneumatic Devices. GPA Midstream representatives provided information
regarding air-driven pneumatic controllers. They stated that while some
equipment may be air-driven, many sites still retain natural gas-driven
pneumatic controllers for certain equipment for safety reasons. They
noted that some facilities may use all air-driven devices, but this
requires two air compressors and back-up power, so it is usually only
used at new facilities designed specifically to use only air-driven
devices. GPA Midstream representatives also explained that conversion to
air-driven pneumatic controllers at existing facilities is not simple;
the conversion would require 3-phase power available at the site, an air
compressor (which typically costs about $80,000), and additional air
pipelines to be installed to each converted device, so these retrofits
can be extremely expensive. 

	Pressurized Liquid Sampling. GPA Midstream representatives expressed
concern over the selected pressurized liquid sampling method (CARB) for
the ICR. They cited high cost and laboratory inexperience as their main
concerns.  GPA Midstream suggested GPA Method 2174 for sample collection
and GPA Method 2103 for sample analysis as an alternative.



Attachment 1

Participants in August 25, 2016 EPA/GPA Midstream Meeting

GPA Midstream Representatives

Adrienne Sandoval, Tesoro Corporation

David Oldacker, Enterprise Products Partners

Jaron Hill, The Williams Companies, Inc.

Jeff Stoval, Crestwood Equity Partners

Kale Hanner, ONEOK

Laura Guthrie, Enable Midstream Partners

Laura Higgins, DCP Midstream

Matt Hite, GPA Midstream

Melanie Roberts, Targa Midstream Services, L.P. 

U.S. EPA Representatives

Angie Carey

Brenda Shine

Bruce Moore

Chris Stoneman

Gerri Garwood

Greg Nizich

Jason Dewees

Jodi Howard

Jonathan Witt

Justin Pryor

Lisa Thompson

Mark DeFigueiredo

RTI International (EPA Contractor)

Jeff Coburn

Cassy Becker

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