Date:	September 8, 2016

To:	Brenda Shine, EPA/OAQPS/SPPD

From:	Jonathan Witt, EPA/OAQPS/SPPD

Subject:	Meeting Record for September 8, 2016 meeting between
Representatives of EDF and Representatives of OAQPS (U.S. EPA)



On September 8, 2016, representatives of the U.S. Environmental
Protection Agency (EPA) participated in a call with representatives of
the Environmental Defense Fund (EDF), the Natural Resources Defense
Council (NRDC), the Sierra Club, and the Clean Air Task Force (CATF).
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 CATF on August 2, 2016. The following topics were
discussed.

Part 2 Survey Production Segment Sampling Protocol. EDF representatives
began by requesting that the EPA leverage existing data (e.g. studies,
past data collections, reported data), ensure that data collected is
representative of the entire oil and gas industry, collect data swiftly,
move forward with existing source standards, and ensure transparency and
public disclosure throughout the entire process. EDF reviewed the
production segment stratification options for the Part 2 survey that EPA
proposed in the Federal Register notice on June 3, 2016 (81 FR 35763).
EDF representatives reiterated suggestions within the CATF comments to
change the stratification by sampling facilities from high-producing
basins. There would be eighteen strata: sixteen for basins (3 - 12% of
emissions individually, 92% collectively), one for "other basins", one
for marginal oil wells, and one for marginal gas wells. They also
suggested the stratification of reporters v. non-reporters. EPA
representatives pointed out that comments from trade associations were
also in favor of a separate category for low-producing wells. 

Part 1 Survey. EDF representatives asked that the EPA include additional
questions related to flares, combustors, electricity, well completions,
and workovers on the Part 1 survey. EPA representatives explained that
some of the questions that were originally asked in the Part 1 survey
may be too broad and are considering moving these questions to the Part
2 survey, where more detailed questions can be asked. They further
explained that the purpose of the revised Part 1 is to know how the
production segment is configured and to learn what the major equipment
counts are.

Part 2 Survey: Tanks and Separators. EDF representatives asked that more
information be requested on the “Tanks Separators” tab, including
information on stuck dump valves and the number of days that each tank
has spent operating. EPA representatives explained that they would like
information on pressure relief devices, thief hatches, monitoring
systems, and alarms. They further explained that they are primarily
looking at flashing emissions from when pressurized liquids are dumped
into storage tanks at atmospheric pressure. They also explained the
importance of requiring a standardized method for looking at flashing
emissions.

	Part 2 Survey: Pneumatic Devices. EDF representatives asserted that the
breakdown of pneumatic device classifications into snap-acting v.
throttling and continuous v. intermittent was important for the purposes
of this ICR. EPA representatives agreed, but also explained that the
granular level of detail that was requested in the CATF comments might
not be feasible to include at the time. However, they explained that
they plan to request more granular information wherever they ask for
emissions test data on pneumatic devices. EPA representatives also
pointed out that several studies on pneumatic devices are currently
underway, including one by Eben Thoma in the EPA’s Office of Research
and Development that will be conducted in the Uintah basin. 

Part 2 Survey: Miscellaneous. EPA representatives reiterated that if
respondents report facility-level data in the Greenhouse Gas Reporting
Program (GHGRP) that is also being requested in the ICR, then they do
not have to report that data in the ICR, provided they report their
GHGRP ID. EDF representatives asked for an update on the EPA’s plans
regarding addressing comments on dehydrators. EPA representatives
explained that they did not have any responses to those comments at the
time. With regards to equipment leaks, EDF representatives asked the EPA
to request actual emissions data in the ICR and to combine that data
with 40 CFR Part 98 Subpart W emission factors. EPA representatives
explained that they are requesting emissions data if the respondent
already has it, since it would not be an additional burden for them to
report it. They also explained that wherever they ask for information on
volatile organic compound emissions in the ICR, they also plan to ask
for emissions of benzene, toluene, ethyl benzene, and xylene, as well as
hexane and methanol where applicable. In addition, EPA representatives
explained that they plan to introduce a methodology for reducing the
sampling burden on the transmission and storage segments and asking more
questions on compressor drivers.

	Timing. EDF representatives asked if there was an update on the timing
requirements for responding to the ICR. EPA representatives explained
that no timing decisions had been made. 

Attachment 1

Participants in September 8, 2016 EPA/EDF Meeting

EDF Representatives

David Lyon

Hillary Hull

Peter Zalzal

NRDC Representatives

Briana Mordick

Meleah Geertsma

Sierra Club Representatives

Andres Restrepo

CATF Representatives

Darin Schroeder

U.S. EPA Representatives

Alison Davis

Amy Hambrick

Angie Carey

Beth Miller

Brenda Shine

Jonathan Witt

Lisa Thompson

Mark DeFigueiredo

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