May 18,2015 Memorandum Subject: May 13,2015 Meeting Betweenthe American Petroleum Institute (API), API Members and the U.S. Environmental ProtectionAgency (EPA)



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### ChriWtJ'~man, Policy Advisor Outreach and Information Division, Office ofAir Quality Planning and Standards (OAQPS) To: Docket- EPA-HQ-OAR-2011-0151 This memorandum to docket provides a briefsummary ofthe maindiscussionpoints made at the subject meeting for an upcoming proposed rulemaking onthe permitting of minor oil and natural gas minor sources in Indian country. Meeting details: When: May 13, 2015; 1:00-2:00p.m. ET Where: EPA Offices, RTP, NC Participants: EPAAttendees Greg Green Chris Stoneman Bruce Moore Greg Nizich Lourdes Morales Laura McKelvey API Attendees Tom Monahan, XTO Karen Pratt, XTO JeffAdams, BP ShankarAnanthakrishna, Chevron MarkBareta, Williams Jason Zapalac, Anadarko Mike O'Connor, XTO Doug Deason, ExxonMobil Jenny Yang, ConocoPhillips AdamBerig, Encana Matt Todd, API

API Phone Participants Bill Wehrum, Hunton & Williams Sherrie McGowan, ConocoPhillips Ryan Streams, WEA AngelaZivkovich, Anadarko Amanda SanMiguel, Marathon Oil Grover Campbell, Devon NicaHoshijo, WPX The EPA met with API and its members at the energy organization's request. During the meeting, several topics were discussed related to two EPA actions:

• "General Permits and Permits byRule for the Federal Minor New Source Review Program in Indian Country for Five Source Categories; Final Rule," (80 FR 25068, May 1, 2015); and• Advance Notice ofProposed Rulemaking: "ManagingEmissions from Oil and Natural Gas Productionin Indian Country," (79 Federal Register 32502, June 5, 2104). Thetopics were:

• Creation ofsynthetic minor sources using streamlinedpermitting approaches; • Processes and requirements related to the Endangered Species Act and the National Historic Preservation Act; • EPA's approach for setting levels ofcontrol in final general permits and permits by rule for Indian country; • Inclusion ofnonattainmentprovisions in final general permits and permits by rule for Indian country; • The appropriateness ofthroughput limits for the oil and natural gas sector; • EPA's handling ofsource co-location in its final general permits for Indian country; • EPA's handling ofup-front approval for multiple source locations in its final general permits for Indian country; • EPA's decisionto remove setbacks inits final general permits for Indian country; • Treatment ofexisting sources in EPA's upcoming, proposed permitting approach for oil and natural gas sources; • Casting a wider net interms ofcomment sought in EPA's upcoming, proposed permitting approach for oil and natural gas sources; • Issues concerning the CleanAir Act general conformity requirement and the oil and natural gas sector; and • Ability to re-locate engines from site to site inthe oil and natural gas sector. The EPA answered basic questions about its thinking onhow it will address issues of concernto API and its members and offered to be available for further discussions and/or exchanges oftechnical information. This memorandum will be filed in the docket for the above actions and will be available for public review.