Memorandum Subject:

From:

To: July 29 20-1.4

July 17, 2014 Meeting Betweenthe Western Energy Alliance and its Members and the U.S. Environmental Protection Agency (EPA) Chris Stoneman, Policy Advisor



## ~ **~** Outreach and Information Division, Office ofAir Quality Planning and Standards (OAQPS) Docket- EPA-HQ-OAR-2011-0151 This memorandum to docketprovides a briefsummary ofthe main discussionpoints made at the subject meeting during the commentperiod for the Advance Notice of Proposed Rulemaking (ANPR): "ManagingEmissions from Oil and Natural Gas Production in Indian Country." (79 Federal Register 32502, June 5, 2104) Meeting details: When: July 17, 2014; 3:00-4:00p.m. ET Where: EPA Offices, RTP, NC Participants: Chris Stoneman, EPA, OAQPS Cindy Beeler, EPA, Region 8 LauraMcKelvey, EPA, OAQPS Deirdre Rothery, EPA, Region 8 Bob King, WPX Energy Bret Gallo, Bison Engineering Chad Powell, LT Environmental CraigAllison, XTO Curtis Rice, EOG Daubs Thompson, Greenberg Traurig Dave Scott, Beatty & Wozniak Doug Renderer, Newfield Exploration DrewHall, Halcon Emily DeGrasse, Crescent Point Energy Greg Schrab, SM Energy Jagadeesan Sethuraman, Whiting Petroleum Jennifer McQueen, LT Environmental JenniferNajjir, Davis Graham & Stubbs Jessica Berg, Gasco Energy Jill Cooper, Anadarko JuliaJones, Anadarko Karen Pratt, XTO Katherine Doolittle, Anadarko Kristin Dickinson, Enerplus 

## '·NicaHoshijo, WPX Ray Gorka, Slawson Rick Matar, WPX Rob Thompson, Greenberg Traurig Ron LePlatt, QEP Resources Rusty Frishmuth, Bill Barrett Scott Mason, Enerplus Shane Schulz, QEP Resources Steve VanOotegham, Halcon Resources Todd Rudolph, Ultra Petroleum Tom Monohan, XTO Energy Tristan Walker, Halcon Ursula Rick, Western Energy Alliance (WEA) The EPA met with WEA at the energy organization's request. During the meeting, EPA provided an overview ofseveral key aspects ofthe minor source general permitprogram for Indian country and the· recently-issued ANPR for New Source review (NSR) minor source oil and natural gas activity in Indian country. During the course ofthe meeting the WesternEnergy Alliance and its members raised several questions that were discussed (see attached agenda):

• Whether EPA's recently-proposed general permit for engines applies to the oil and gas sector; • Need for a post-constructionpermitting approach that would have controls in place at start-up when productionrates and emissions are the highest but would allow industry to understand the annual emissions at a given well before determining the type ofpermit required; • The way states permit minor sources in the oil and natural gas sector; • Different approaches for permitting minor oil and natural gas sources in Indian count!)'; • Higher**co~ts** associated with retrofitting older wells with control equipment; • The use ofsynthetic minor sources in the oil and natural gas sector; • Improved coordination betweenthe Bureau ofIndian Affairs, the Bureau ofLand Management and the EPA in the approval ofoil and gas activities in Indian country and onpublic lands; and • Role ofthe Bureau ofIndian Affairs and the Bureau ofLand Management in the approval ofoil and gas activities in Indian country and onpublic lands; and • Howto structure a general permit/permit by rule that must cover several different, diverse parts ofIndian country, and different basin characteristics with oil and natural gas activity. The EPA answered basic questions about the content ofthe ANPR and offered to be available for further discussions and/or exchanges oftechnical information. This memorandum will be filed in the docket for the proposed rule and will be available for public review.