MEMORANDUM

Date: November 1 , 2011

Subject: Summary of discussion from the October 21 , 2011, m eeting bet ween the

Sierra Club and the Environmental Protection Agency on the Oil and

Natural Gas Risk and Technology Review

From: Greg Nizich, EPA/OAQPS/SPPD/FIG

To: EPA Docket ID: EPA

- HQ

- OAR

- 2010

- 0505

I. PURPOSE

This memorandum summarizes the October 21

, 2011 tele

- conference between the

Environmental Protection Agency (EPA) and representatives from the Sierra Club

. The purpose

of this call was to listen to comments and concerns from the Sierra Club regarding the August

23, 2011, Oil and Natural Gas Sector proposed rules

.

II. DATE

The call took place between 1 :00 p m and 2: 3 0 pm on October 21 , 2011 at the Research

Triangle Park, NC, campus of t he U

. S

. EPA.

III. ATTENDEES

The following individu als attended the tele

- conference :

Sierra Club

Emma Cheuse

Devorah Ancel

National Resources Defense Council

Miriam Rotkin

- Ellman

Avi Kar

Clean Air Task F orce

Praveen Amar

Bruce Buckheit2

U.S. Environmental Protection Agency

Bruce Moore

Greg Nizich

Mark Morris

IV. SUMMARY OF DI SC USSION

Bruce Moore began the meeting by saying that since the discussion was taking place between

proposal and promulgation, EPA canno t respond to comments, but can listen to the i ssues raised

during the meeting and provide clarifying information. The following is a summary of the topics

raised by the Sierra Club :

1) Emissions Data and sources used other than the 2005 National Emissions Inventory (NEI)

data

. Concern that 2005 data i sn’t representative with recent increases in oil and natural gas

production. The Sierra Club asked about other studies that we re compare d to NEI data.

2) An observation that certain p ollutants we re removed from the NE I data for the source

category

. EPA stated that certain sources we re removed from the data base if they we re not part

of the source category (e.g., internal combustion engines)

.

3 ) Risk Analysis

– O ther carcinogens evaluated in addition to the risk driv er. EPA stated that the

docket contains all risk modeling inputs, and the risk report contains summary output

information for each facility, as well as the cancer driver for the MIR, and incidence drivers.

The inputs could be examined to see which HAP wer e modeled. EPA clarified that the docket

does not contain complete model ing output data for each facility. A cancer risk

- driver file that

gives the cancer risk drivers for each facility is not in the docket

. A need for a summary of

cancer risk across the s ector was also expressed

.

4 ) C oncern with emissions of hydraulic fracking compounds and that 25

- 28 hazardous air

pollutant (HAP) compounds are listed in a government report.

5 ) EPA should be addressing other emission points other than dehy drator s, storage vessels and

leaking equipment

.

6 ) T he 10% VHAP exemption and the affected facility definition in subpart OOOO needed

further revision

.

7 ) A need for additional information concerning the table of emission points for facilitywide risk

and how those values we re calculated.

8 ) Clarification in the MACT allowable assessment whether only emissions of benzene are

increased or if other HAP are increased proportionately too

.

9 ) Clarification if naphthalene i s considered in the multi

- pathway assessment.3

10 ) A question whether the acute risk analysis used MACT allowable emissions too. EPA said it

did not due to the conservative approach for the acute assessment

.

11 ) A comment that the r esidual ri sk table lists canc er drivers, but that t here are some

compounds listed such as xylene and toluene that shouldn't be there. EPA agreed

.

12 ) A request for clarification in the transmission and storage (i.e., 40 CFR 63 subpart HHH ) risk

discussion regarding E PA ’ s explanation of the risk reduction of the MIR from 90 to 20

- in

- 1

-

million

. The Sierra Club referred to Table 3 in the docket item ending in 0077, the tech nical

review memo for MACT.

13 ) A question about the multi

- pathway assessment period of 50 yr s. vs. the 70 yrs. for cancer

assessment

. EPA stated that i t assum e s a facility emits for 50 years for the pu rposes of the multi

pathway modeling.

14 ) The use of emissions of BTEX as a surrogate for regulated HAP for small glycol

dehy drators

. EPA b elieved that only complete emi ssions data for BTEX was in our dataset and

that reduction of BTEX would result in corresponding reductions for other HAP.

15 ) T he MACT review for new LDAR sources should be based on a BACT determination in

EPA’s RBL Clearinghouse for valves.

16 ) A que stion concerning the dollars/ton of emission reduction being the decision criteria and

not other metrics that might include risk

- based factors.

17 ) Concerns that the existing excused excursion language in sections 63.773(d) and 63.1283(d)

conflict s with the removal of startup, shutdown and malfunction provisions in other sections of

the proposed rules

.

18 ) A question about why different meteorological data wasn’t used

. EPA stated that the most

appropriate data available for a given locati on is used

.

19 ) A comment regarding exposure to children below a certain age.