May 18,2015 

Memorandum 

Subject: May 13,2015 Meeting Between the American Petroleum Institute (API), 

API Members and the U.S. Environmental Protection Agency (EPA) 

l.~~ 

From: ChriWtJ'~man, Policy Advisor 

Outreach and Information Division, 

Office of Air Quality Planning and Standards (OAQPS) 

To: Docket- EPA-HQ-OAR-2011-0151 

This memorandum to docket provides a brief summary of the main discussion points 

made at the subject meeting for an upcoming proposed rulemaking on the permitting of 

minor oil and natural gas minor sources in Indian country. 

Meeting details: 

When: May 13, 2015; 1:00-2:00 p.m. ET 

Where: EPA Offices, RTP, NC 

Participants: 

EPA Attendees 

Greg Green 

Chris Stoneman 

Bruce Moore 

Greg Nizich 

Lourdes Morales 

Laura McKelvey 

API Attendees 

Tom Monahan, XTO 

Karen Pratt, XTO 

Jeff Adams, BP 

Shankar Ananthakrishna, Chevron 

Mark Bareta, Williams 

Jason Zapalac, Anadarko 

Mike O'Connor, XTO 

Doug Deason, ExxonMobil 

Jenny Yang, ConocoPhillips 

Adam Berig, Encana 

Matt Todd, API 

API Phone Participants 

Bill Wehrum, Hunton & Williams 

Sherrie McGowan, ConocoPhillips 

Ryan Streams, WEA 

Angela Zivkovich, Anadarko 

Amanda San Miguel, Marathon Oil 

Grover Campbell, Devon 

Nica Hoshijo, 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 by Rule 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 of Proposed Rulemaking: "Managing Emissions from Oil and 

Natural Gas Production in Indian Country," (79 Federal Register 32502, June 5, 

2104). 

The topics were: 

• Creation of synthetic minor sources using streamlined permitting approaches; 

• Processes and requirements related to the Endangered Species Act and the 

National Historic Preservation Act; 

• EPA's approach for setting levels of control in final general permits and permits 

by rule for Indian country; 

• Inclusion of nonattainment provisions in final general permits and permits by rule 

for Indian country; 

• The appropriateness of throughput limits for the oil and natural gas sector; 

• EPA's handling of source co-location in its final general permits for Indian 

country; 

• EPA's handling of up-front approval for multiple source locations in its final 

general permits for Indian country; 

• EPA's decision to remove setbacks in its final general permits for Indian country; 

• Treatment of existing sources in EPA's upcoming, proposed permitting approach 

for oil and natural gas sources; 

• Casting a wider net in terms of comment sought in EPA's upcoming, proposed 

permitting approach for oil and natural gas sources; 

• Issues concerning the Clean Air Act general conformity requirement and the oil 

and natural gas sector; and 

• Ability to re-locate engines from site to site in the oil and natural gas sector. 

The EPA answered basic questions about its thinking on how it will address issues of 

concern to API and its members and offered to be available for further discussions and/or 

exchanges of technical information. 

This memorandum will be filed in the docket for the above actions and will be available 

for public review.