### 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 Stoneman, Senior Policy Advisor

# ~**~** Outreach and Information Division, Office ofAir Quality Planning and Standards (OAQPS) Docket- EPA-HQ-OAR-2014-0606 This memorandum to docket provides a briefsummary ofthe 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 ofthe four recently signed oil and natural gas proposed actions (see attached agenda). After presenting the proposed rulemaking mentioned above (one ofthe 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 Damberg, Office ofAir Quality Planning and Standards (10 mins.) The Data Requirements Rule (DRR) was signed by the EPA Administrator on August 10, 2015 andwaspublished 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 tonsperyear or greater). The DRR sets aprocess and timetablefor air agencies to either establish ambient monitoring sites or conduct air quality modeling, andsubmit 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 andcompliance to EPA byJanuary 13, 2017. 

### 2. Appendix W- Presenter: George Bridgers, Office ofAir Quality Planning and Standards (10 mins.) (Presentation) The EPA isproposing to revise the Guideline onAir Quality Models (Appendix W to 40 CFR Part

**~2)**for thefirst time since 2005. Theproposed revisions address numerous changes in the regulated air quality modeling community over thepast decade including changes in the form andaveraging time of the NAAQS andneed for new techniques to address secondarily formed PM2. 5 andozone. Numerous other streamlining changes areproposedthat should clarify and, in many cases, simplify the regulatory requirements for regulatory dispersion and implementationplan compliance demonstrations. 

### 3. Proposed Rule: Determinations ofAttainment by the Attainment Date, Extensions ofthe Attainment Date, and Reclassification ofSeveral Areas Classified as Marginal for the 2008 Ozone National Ambient Air Quality Standards (NAAQS) Presenter: Lynn Dail, Office ofAir Quality Planning and Standards (10 mins.)



### 1The EPA isproposing three separate and independent determinations related to the 36 areas that are currently classifiedas "Marginal" for the 2008 ozone NAAQS. First, the EPA isproposing to determine that 17areas attained the 2008 ozone NAAQS by the applicable attainment date, July 20, 2015. Second, the EPA isproposing to grant 1-year attainment date extensions for 8 areas on the basis that the requirements for such extensions under the Clean AirAct have been met. Third, the EPA isproposing to determine that 11 areas havefailed 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 submitState Implementation Plan (SIP) revisions that meet the statutory andregulatory requirements that apply to 2008 ozone nonattainment areas classifiedas Moderate. In this action, the EPA is proposing andtaking comment on two options for the deadline by which states wouldneedto submit to the EPAfor review andapproval the SIP revisions required for Moderate areas once their areas are reclassified. 

### 4. CPP- Proposed Federal Plan- Presenter: Toni Jones, Office ofAir Quality Planning and Standards (10 mins.) On August 3, theproposal was signed for thefederalplan for the Clean Power Plan that will also serve as a model rule for states developing their stateplans. EPA is co -proposing two differentplan types for afederalplan to implement the Clean Power Plan emission guidelines (a rate -based tradingplan anda massbased tradingplan), and bothproposed 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 ofAir Quality Planning and Standards (10 mins.) (Presentation) On August 14, 2015, the US. Environmental ProtectionAgency (EPA) issued two proposals tofurther reduce emissions of methane-rich gas from municipal solid waste (MSW) landfills. Theproposals wouldrequire new, modifiedand 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 ofAir Quality Planning and Standards (10 mins.) (Presentation) On August 18, 2015, the US. Environmental ProtectionAgency (EPA)proposed afederalplan to implement the Federal Minor New Source Review Program in Indian Country for oil and natural gasproduction. Theproposed plan would limit emissions of harmful airpollution while making thepreconstructionpermitting process for this rapidly growing industry more efficient. EPA also isproposing to

2extend the deadline by which oil and natural gas sources must obtain minor NSR permits. 

### 7. Proposed NSPS - Presenter: Amy Hambrick, Office ofAir Quality Planning and Standards (10 mins.) TheproposedNSPS that requires methane and VOC reductions from across the oil andnatural gas sector andrequires owners/operators tofind 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 ofAir Quality Planning and Standards (10 mins.) OnAugust 

### 18,2015, EPA made the draft Control Techniques Guidelinesfor the Oil andNatural Gas Industry available for comments. The draft CTGprovides reasonably available control technology recommendations for storage vessels, pneumatic controllers, pneumaticpiifnps --;centr1fugal

## ana reciptocattng compressors, equipment leaks from natural gasprocessingplants and fugitive emissions. Implementation of the CTG recommendations would extend VOC reduction requirements to existing oil andnaturalgas sources in ozone nonattainment areas classifiedas Moderate (and above) andstates in the Ozone Transport Region. 9. 

### Source Determination -Notice ofProposed Rulemaking (NPRM)

- Presenter: Raj Rao, Office ofAir Quality Planning and Standards (10 mins) EPA hasproposed the Source Determination rule to clarifY the EPA 's air permitting rules as they apply to the oil and natural gas industry.

Due to conflictingNTAA andEPA meetings onAugust

### 27th, the AirPolicy 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 29 1 h.

3