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RIncorporated Providing Environmental Technical Support Since 1989

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- 0122 MEMORANDUM

DATE: August 1, 2013

SUBJECT: Summary of June 20 , 2013, Meeting with Representatives from the Gas Processors Association (GPA)

FROM: Heather P. Brown, EC/R Incorporated

TO: Bruce Moore, EPA/OAQPS/SPPD/FIG

I. PURPOSE

This memorandum summarizes the June 20 , 2013 meeting between the Environmental Protection Agency (EPA) and industry representatives from the Gas Processors Association ( G PA). Th e intent of the meeting was to allow GPA to clarify the ir comments submitted to EPA, dated May
28, 2013, 1 regarding EPA’s April 12, 2013, proposed amendments.

II. DATE The meeting took place on June 20 , 2013, at 9 :00 am at the EPA building in the Research Triangle Park, NC. Several industry members participated via telephone.

III. ATTENDEES

The following individuals participated in the meeting :

Industry Representatives

Jeff Adams, BP Grover Campbell, Chesapeake Jerry Dismukes, Whiting

Shawn Fullingim, Enogex Kaitlin Gregg, Van Ness Feldman Laura L. Guthrie, CenterPoint Energy Gas Transmission Shyla Harris, Whiting Oil and Gas Corporation Alena Jonas, ConocoPhillips Julie Lang, Prism Lori Marquez, ConocoPhillips Mark Peak, QEP
Brent Peterson, Atlas Pipeline Daniel Pring, QEP

1 Letter from Applekamp, J., Director, Governmental Affairs, Gas Processors Association , Tulsa, OK to EPA Docket Center, Washington, DC. Comments of the Gas Processors Association Regarding the O il and Natural Gas Sector: Reconsideration of Certain Provisions of New Source Performance Standards; Proposed Rule, 78 Fed. Reg. 22,126 (April 12, 2013) . May 28, 2013. EPA Docket No.EPA

- HQ

- OAR

- 2010

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- 4615.2 Gabriela Vega , QEP Laura Weber, DCP

U.S. Environmental Protection Agency (EPA)

Bruce Moore , Office of Air Quality Planning and Standards (OAQPS) Chris Frantz, OAQPS Charlene Spells, OAQPS David Cozzie, OAQPS

EC/R Incorporated

Heather Brown

IV. SUMMARY OF DISCUSSION

EPA and GPA made the following comments regarding permit burden :

• Kansas is holding off on issuing permits until the rule is finalized.

• Rulemaking is viewed as a way of easing permit burden for the Oil and Gas Industry.

• States, including but not limited to

, Kansas and Oklahoma are required to obtain state permits for NSPS affected facilities.

• Owners /operators must obtain permits for facilities affected and permits to keep facilities

from being classified as an affected facility

.

GPA discussed their May 2013 comments and addressed the issues described below. GPA discussed their “Critical Issues List,” as foll ows:

• The “events” described in 60.5395(b)(2) that trigger control requirements for Group 1 tanks should be more specific for storage vessels at well sites. Only the events described in (b)(2)(i) through (iii) should be considered triggered events for stor age vessels that store reservoir fluids (i.e., at well sites, tank batteries, centralized production facilities).

o M idstream storage vessels comprise approximately 1% to 2% of the total population of Oil and Gas storage vessels.

o GPA proposed a set date of April 15, 2015 (instead of April 12, 2013) whereby Group 1 storage vessels with the potential to emit VOC emissions (downstream) equal to or greater than 6 tpy must comply with 60.5395(d) through (g).

 Even though a tank emits <6 tpy of VOC it still needs to be equipped with a control device and it still impacts the availability of control devices (e.g., moving from one regulatory mechanisms).

 Midstream operations are more likely to incorporate vapor recovery units (VRUs).

o The date upon which owner s /operator s must begin to track “triggering events”

should allow time for initial determination o f potential VOC emissions rate.

 Additional time would allow owners/operators the opportunity to obtain state permits.

 According to GPA, l ong lead times are often an indication of a shor tage of supply. It will take large companies up to 9 months to obtain control devices; meanwhile some smaller companies might not be able get control

devices at all.3 • The storage vessel alternative control requirement that allows for the use of vapor recovery to a flow line must be modified to be applicable to Midstream storage vessels.

o In the August 16, 2012 finalized NSPS OOOO the term “flow line” is only used within the context of gas well affected facil ities. To address this issue, GPA suggested the following :

 Modify the definition of the term “flow line;” or

 Modify the rule language wherever the alternative compliance option is addressed (i.e., substitute “flow line, or to a process natural gas line” everywhere “flow line” is mentioned).

o Industry uses the term “flow line” as it is currently defined, so to modify the

definition could further confuse them.

• The provision that storage vessels that decrease emissions below 6 tpy VOC remain an

affected sou rce should be limited in two ways to avoid unintended recordkeeping

burdens.

o E missions are completely dependent on operations at the facility so moving the tank should be allowed to reevaluate the emissions to determine affected facility

status.

 Relocati on alone does not make it a new source under the NSPS.

 Tank emissions are highly dependent on the flow rate at the facility and

condensat e composition, so each time the tank is moved it needs to be

reevaluated.

• When §60.5412(a) was modified to apply only to centrifugal compressor affected facilities, and 60.5412(d) was added for storage vessel affected facilities, it became unclear what needs to be done when using a flare as a control device for a storage vessel affected facility.

• In regard s to closed vented systems (CVS ) that recover vapors, the concept of “operational 95% of the year” is achievable if the term “operational” is changed or interpreted to mean “capable of being operated when the storage vessel affected facility is

in service. ”

• A flare or enclosed combustion device should only be required to be in operation when there is flow into the storage vessel affected facility.

o GPA recommended modifying 60.5412(d)(3) to include “there is flow into the storage vessel causing,” so that it is clear when operating a control device a flare or an enclosed combustion device should only run when there is a flow into the

st orage vessel affected facility.

• According to GPA, there are some inconsistencies and redundancy in the requirements

for init ial, continuous, recordkeeping and reporting requirements, as well as, the references in the affected facility standards, which they claim adds unnecessary bulk to

the rule.4 • In regards to requirements for CVSs, GPA believes that the references found in 6 0.5411

and 60.5416 are not consistent.

• If a storage vessel is not an affected source due to emissions of less than 6 tpy VOC, and emissions increase to 6 tpy or greater, when must the storage vessel be in compliance with the §60.5395 standards?

• Based on EPA’s determination th at BSER is required at 6 tpy and not at 4 t p y , GPA believes that the trigger for reinstalling a storage vessel affected facility co ntrol device

should also be 6 t p y

.

• In orde r to avoid unnecessary duplication of reporting, the notif ications for Group 1 storage vessel affected facilities should be specified as being due with the initial annual report (90 days after October 15, 2013).

• GPA would prefer if EPA allows manufacturer’s records to be maintained offsite.

• To ensure consiste ncy with 60.5365(e) GPA recommended modifying 60.5395(c)(1) and (2) to include “taking into account requirements under legally and practically enforceable limits in a permit or by other mechanism.”

• According to GPA, the compliance requirements found in 60.5395(g) are unclear. They recommended that EPA explain the requirements more clearly.

GPA responded to EPA ’s solicitation of comments in the preamble to the proposed amendments,

as follows :

• S torage vessels installed in emergency situations (i.e., due to failure)

.

• GPA supports the proposal for an alternative, mass

- based numeric limit on uncontrolled emissions of 4 tpy. GPA explained that EPA has put forth sound reasoning for the alternative limit; freeing up scarce control equipment where emissions ha ve been proven to be significantly below the 6 tpy applicability threshold for controls. However, GPA also requests that re

- installation of controls should not be required until uncontrolled emissions again reach 6 tpy as for a new storage vessel