### Memorandum Subject:
From:

To: August 4

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July 31, 2014 Meeting Betweenthe American Petroleum Institute (API), API Members and the U.S. Environmental ProtectionAgency (EPA) Chris Stoneman, Policy Advisor

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**ft~** Outreach and InformationDivision, Office ofAir QualityPlanning and Standards (OAQPS) Docket- EPA-HQ-OAR-2011-0151 This memorandum to docket provides a briefsummary ofthe main discussionpoints made at the subject meeting during the commentperiod for the Advance Notice of Proposed Rulemaking (ANPR): "Managing Emissions from Oil and Natural Gas Production in Indian Country." (79 Federal Register 32502, June 5, 2104) Meeting details: When: July 31, 2014; 10:30-12:00p.m. ET Where: EPA Offices, RTP, NC Participants: Gregory Green, EPA, Region 8 LauraBunte, EPA, OAQPS Bruce Moore, EPA, OAQPS Chris Frantz, EPA, OAQPS MatthewTodd, API (and other API participants) Bill Wehrum, Hunton and Williams API members:XTO, Anadarko, Chevron, Shell, Marathon, ConocoPhillips, Enterprise Products, WPX Energy, and BP The EPA met with API and its members at the energy organization's request. During the meeting, EPAprovided an overview ofseveral key aspects ofthe minor source general permitprogram for Indian country and the recently-issued ANPR for New Source
.review minor source oil and natural gas activity in Indian country. During the course ofthe meeting the Western Energy Alliance and its members raised several questions that are summarized in the attached agenda. The EPA answered basic questions aboutthe content ofthe ANPR and offered to be available for further discussions and/or exchanges oftechnical information. This memorandum will be filed inthe docket for theproposed rule and will be available for public review.**-= ===**  **======= =F~**  **I"'Meeting** to DlstuSS the Tribal Minor

### NSR ANPR July 31, 2014
I. Introductions II. Update from EPA on the Tribal Minor NSR permit forthe O&G sector. 1. Schedule for completing the permit? 2. Does the Agency have a preferred approach (GP, PBR, FIP)? 3. What is EPA thinking with regard to existing sources? 4. Is EPA planning on taking final action with regard to synthetic minorsources? 5. Is EPA thinking about adopting permits for both attainmentand nonattainment areas? 6. What information/ideas do you need from API? Ill. API's preliminary thoughts on the ANPR and related issues. 1. Existing Sources EPA should focus for now on issuing atribal minor NSR permitfor O&G sources. The need to control existing sources depends on local air quality conditions. Ifexisting source controls are needed within adesignated non-attainmentarea, they should be tailored to address the local needs and conditions. The Fort Berthold FIP is not an appropriate model. 2. Permits for NonattainmentAreas The permit should include appropriate additional conditions for sources that are constructed or modified in nonattainment areas. After designation ofan area to nonattainment, no additional rulemaking or regulatory action should be needed forthe nonattainment permit to be available to affected sources. 3. Permitting Method a. A FIP (containing requirementsjustforconstruction or modification) ora PBR offer advantages€}GP. b. An affected source should be able to optfor an individual permit. 4. Permit Issuance · Permit issuance should be streamlined so as notto delay construction or modification activities. Post-construction notification should be adequate.



### - 1-a. Applicable NSPS or NESHAPs should be adequate for affected equipment. b
. Where NSPS or NESHAPs do not apply, commonly available control measures should apply.
c. Where multiple control measures are available, the affected source should be able to select from amongthe choices. d. Affected sources should be able to certifyto emissions rates orcontrol

· measures as needed to establish synthetic minorstatus.
e. Permit limits should be emission limits orwork practices, not capacity limits (e.g., engine GP proposal). 6. Pollutants The permit should cover all relevant regulated NSR pollutants and be available to establish effective limits on HAPs for synthetic minors. IV. Conclusion and Next Steps



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