Date:	September 22, 2016

To:	Brenda Shine, EPA/OAQPS/SPPD

From:	Jeff Coburn 

Subject:	Meeting Record for August 31, 2016 meeting between
Representatives of American Petroleum Institute (API) and
Representatives of the U.S. Environmental Protection Agency (EPA)



On August 31, 2016, representatives of the EPA and their contractor (RTI
International) participated in a meeting with representatives of 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). The following
topics were discussed.

Timing. API representatives requested an update on the timing of the
ICR. EPA representatives noted that public commenters provided good
rationale for extending the response deadlines but that no timing
decisions had been made.

Part 2 Sampling Approach. API representatives reiterated their public
comment recommendations to use the gas to oil ratio groupings and to
develop a separate “stripper well” (wells producing less than 15
barrel day of oil equivalence) category. They also recommended that the
EPA reduce the number of facilities sampled in the stripper well, dry
gas well, and coal bed methane (CBM) well categories because these well
types did not have much equipment at the well site and would be,
therefore, less variable. 

Definition of Facility. API representatives stated that the proposed
definition of facility is too broad that the EPA should limit production
facilities to the well site (disturbed area around the well pad and
associated equipment in that area) and the “centralized production”
tank battery. API representatives presented a diagram of a production
area in California where approximately 10,000 heavy oil stripper wells
produced liquids to two centralized production areas. If a
“facility” was defined as all of the interconnected wells supplying
a centralized tank battery, this facility would have to report for
thousands of wells, creating undue burden for the respondent and highly
skewing the data set towards heavy oil stripper wells. While API
representatives noted that this was an extreme example, other facilities
exist where hundreds of wells produce to the same centralized tank
battery. API representatives stated that the recent source determination
rule is only applicable to new sources, so the “connected and
adjacent” provisions in the source determination rule are not really
applicable to existing facilities. API representatives noted that, in
the California site example, most of the wells were either permitted
separately or were “well head only” sites that did not require
permits. API representatives suggested that the definition of a facility
for production facilities be a well site and its associated production
area.   

Economic Questions. EPA representatives noted that there were several
comments that suggested that the EPA collect economic data on the
operations of the well to inform the “remaining useful life” of the
well site. API representatives indicated that these types of questions
were reasonable but would likely be considered confidential business
information. They also noted that the question regarding the presence of
a flare could be wrongly interpreted to suggest controlling emissions
might be cost effective. First, with the current expansive definition of
facility, the flare may be miles away from a given source. Second, some
equipment, such as older tanks, might not be retrofit-able to a control
device and would have to be replaced if the emissions from the tank were
required to be controlled.  

Liquids Unloading. API representatives suggested that the EPA drop or
limit questions regarding liquids unloading. According the API
representatives, liquids unloading is a technical issue related to well
production and not an emissions control issue. API representatives
stated that liquids unloading using artificial lift systems should not
be included in the ICR because they are not an emissions source and are
automated such that operators may not know specifically when liquids
unloading was being performed. The also noted that the type of liquids
unloading systems were highly dependent on well depth, well drilling
type (vertical versus directional), reservoir pressure and other issues.
API representatives noted that the EPA in the New Source Performance
Standards subpart OOOOa and State agencies have elected not to regulate
liquids unloading due to the technical issues, and they offered to
provide the EPA with a webinar that they had used previously for
describing the complexities of liquids unloading. API representatives
confirmed that liquids unloading could be an issue for dry gas and CBM
wells. The EPA representative expressed interest in learning more about
liquids unloading and recommended that API provide the suggested liquids
unloading webinar.



Attachment 1

Participants in August 31, 2016 EPA/API Meeting

API Representatives

Shankar Ananthakrishna, Chevron

Adam Bering, Encana

Rachel Buckbee, BP

Grover Campbell, Devon

Lisa Campbell, ERM

Jim Cooper, Chesapeake

Denise Grubert, ERM

Greg Johnston, Chesapeake

Tom Monahan, XTO

Dennis Newman, Oxy

Laura Perry, ConocoPhillips

Lynn Reed, ONEOK

Vanessa Ryan, Chevron

Matt Todd, API

John Wagner, APIAndy Woerner, ERM

Dana Wood, BP

Angela Zivkovich, Anadarko

U.S. EPA Representatives

David Cozzie

Amy Hambrick

Jodi Howard

Penny Lassiter

Karen Marsh

Bruce Moore

Brenda Shine

Lisa Thompson

Peter Tsirigotis

Matthew Witosky 

Jonathan Witt

RTI International (EPA Contractor)

Jeff Coburn

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