Memorandum 

Subject: 

From: 

To: 

September 25, 2015 

September 10, 2015, Teleconference Between the National Tribal Air 

Association (NTAA) and U.S. Environmental Protection Agency (EPA) 

Christopher 

Outreach and 

Stoneman, 

Information 

Senior 

Division, 

Policy Advisor ~ ~ 

Office of Air Quality Planning and Standards (OAQPS) 

Docket- EPA-HQ-OAR-2014-0606 

This memorandum to docket provides a brief summary of the subject meeting concerning 

the proposed rulemaking: "Review ofNew Sources and Modifications in Indian Country: 

Federal Implementation Plan for Managing Air Emissions from True Minor Sources 

Engaged in Oil and Natural Gas Production in Indian Country." 

Teleconference details: 

When: September 10,2015 

Time: 2:00pm ET 

Participants: Chris Stoneman, EPA OAQPS 

Toni Colon, EPA OAQPS 

Laura McKelvey, EPA OAQPS 

Amy Hambrick, EPA OAQPS 

Charlene Spells, EPA OAQPS 

Raj Rao, EPA OAQPS 

Other EPA OAQPS staff 

NT AA Leadership and Members 

During the teleconference, EPA provided an overview of the four recently signed oil and 

natural gas proposed actions (see attached agenda). After presenting the proposed 

rulemaking mentioned above (one of the four), EPA expressed a willillgness to answer 

any questions from NTAA participants; no questions were asked. The EPA indicated that 

we would be available to answer questions after the call that NT AA. members may have. 

This memorandum will be filed in the docket for the proposed rule and will be available 

for public review. 
National Tribal Air Association I U.S. EPA 

NTAA- EPA Air Policy Update Call 

Thursday September 101

h, 2015 

10:00 am AK 

2:00pmET 

Call into 1-866-299-3188 

User Code 919-541-5624# 

Webinar Linlc https://attendee.gotowebinar.com/register/6717429275628711937 

AGENDA: 

1. Data Requirements Final Rule- Presenter: Rich Dam berg, Office of Air 

Quality Planning and Standards (10 mins.) 

The Data Requirements Rule (DRR) was signed by the EPA Administrator on 

August 10, 2015 and was published in the Federal Register on August 21, 2015 

(See 80 FR 51052). The DRR directs state and tribal air agencies to characterize 

current air quality in areas with large S02 sources (emitting 2, 000 tons per year 

or greater). The DRR sets a process and timetable for air agencies to either 

establish ambient monitoring sites or conduct air quality modeling, and submit 

air quality data to the EPA. Alternatively, an air agency can avoid the air quality 

characterization requirement under the rule by establishingfederally enforceable 

emission limits and providing documentation of the limit and compliance to EPA 

by January 13, 2017. 

2. Appendix W- Presenter: George Bridgers, Office of Air Quality Planning 

and Standards (10 mins.) (Presentation) 

The EPA is proposing to revise the Guideline on Air Quality Models (Appendix W 

to 40 CFR Part ~2) for the first time since 2005. The proposed revisions address 

numerous changes in the regulated air quality modeling community over the past 

decade including changes in the form and averaging time of the NAAQS and need 

for new techniques to address secondarily formed P M2. 5 and ozone. Numerous 

other streamlining changes are proposed that should clarify and, in many cases, 

simplify the regulatory requirements for regulatory dispersion and 

implementation plan compliance demonstrations. 

3. Proposed Rule: Determinations of Attainment by the Attainment Date, 

Extensions of the Attainment Date, and Reclassification of Several Areas 

Classified as Marginal for the 2008 Ozone National Ambient Air Quality 

Standards (NAAQS) 

Presenter: Lynn Dail, Office of Air Quality Planning and Standards (10 

mins.) 

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The EPA is proposing three separate and independent determinations related to 

the 36 areas that are currently classified as "Marginal" for the 2008 ozone 

NAAQS. First, the EPA is proposing to determine that 17 areas attained the 2008 

ozone NAAQS by the applicable attainment date, July 20, 2015. Second, the EPA 

is proposing to grant 1-year attainment date extensions for 8 areas on the basis 

that the requirements for such extensions under the Clean Air Act have been met. 

Third, the EPA is proposing to determine that 11 areas have failed to attain the 

2008 ozone NAAQS by the applicable attainment deadline of July 20, 2015, and 

to reclassify these areas as "Moderate" for the 2008 ozone NAAQS. Once 

reclassified as Moderate, states must submit State Implementation Plan (SIP) 

revisions that meet the statutory and regulatory requirements that apply to 2008 

ozone nonattainment areas classified as Moderate. In this action, the EPA is 

proposing and taking comment on two options for the deadline by which states 

would need to submit to the EPA for review and approval the SIP revisions 

required for Moderate areas once their areas are reclassified. 

4. CPP- Proposed Federal Plan- Presenter: Toni Jones, Office of Air Quality 

Planning and Standards (10 mins.) 

On August 3, the proposal was signed for the federal plan for the Clean Power 

Plan that will also serve as a model rule for states developing their state plans. 

EPA is co -proposing two different plan types for a federal plan to implement the 

Clean Power Plan emission guidelines (a rate -based trading plan and a massbased trading plan), and both proposed plan types would require affected electric 

generating units (EGUs) to meet emission standards set using the C02 emission 

performance rates in the Clean Power Plan. 

5. Landfill Rule- Presenter: Hillary Ward, Office of Air Quality Planning and 

Standards (10 mins.) (Presentation) 

On August 14, 2015, the US. Environmental Protection Agency (EPA) issued two 

proposals to further reduce emissions of methane-rich gas from municipal solid 

waste (MSW) landfills. The proposals would require new, modified and existing 

landfills would begin capturing and controlling landfill gas at emission levels 

nearly a third lower than current requirements. 

ONG Actions (4): 

6. Federal Implementation Plan to implement Federal Minor New Source 

Review Program in for Oil and Natural Gas Production in Indian Country 

Presenter: Chris Stoneman, Office of Air Quality Planning and Standards 

(10 mins.) (Presentation) 

On August 18, 2015, the US. Environmental Protection Agency (EPA) proposed 

a federal plan to implement the Federal Minor New Source Review Program in 

Indian Country for oil and natural gas production. The proposed plan would limit 

emissions of harmful air pollution while making the preconstruction permitting 

process for this rapidly growing industry more efficient. EPA also is proposing to 

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extend the deadline by which oil and natural gas sources must obtain minor NSR 

permits. 

7. Proposed NSPS - Presenter: Amy Hambrick, Office of Air Quality Planning 

and Standards (10 mins.) 

The proposed NSPS that requires methane and VOC reductions from across the 

oil and natural gas sector and requires owners/operators to find and repair 

leaking components. The proposed rule also extends emission reduction 

requirements further "downstream," covering equipment in the natural gas 

transmission segment of the industry that was not regulated in the agency's 2012 

rules. 

8. Draft Control Techniques Guidelines (CTG)- Presenter: Charlene Spells, 

Office of Air Quality Planning and Standards (10 mins.) 

On August 18,2015, EPA made the draft Control Techniques Guidelines for the 

Oil and Natural Gas Industry available for comments. The draft CTG provides 

reasonably available control technology recommendations for storage vessels, 

pneumatic controllers, pneumatic piifnps--; centr1fugal ana reciptocattng 

compressors, equipment leaks from natural gas processing plants and fugitive 

emissions. Implementation of the CTG recommendations would extend VOC 

reduction requirements to existing oil and natural gas sources in ozone 

nonattainment areas classified as Moderate (and above) and states in the Ozone 

Transport Region. 

9. Source Determination -Notice of Proposed Rulemaking (NPRM) -

Presenter: Raj Rao, Office of Air Quality Planning and Standards (10 mins) 

EPA has proposed the Source Determination rule to clarifY the EPA 's air 

permitting rules as they apply to the oil and natural gas industry. 

Due to conflicting NTAA and EPA meetings on August 27th, the Air Policy Update call 

was shifted to September lOth. In addition, the September 24th call will be cancelled 

The regular time slot for NTAAIEPA Air Policy Update calls will resume on October 291

h. 

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