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## / R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 25 0  Chapel Hill, North Carolina 2751 4 Telephone: (919)484

- 0222  Fax: (919) 484

- 0122 MEMORANDUM

Date: September 14 , 2010

Subject: Summary of the September 9, 2010 Phone Conference with American

Petroleum Institute

From: Denise Grubert, EC/R Incorporated

To: Bruce Moore, EPA/OAQPS/SPPD/CCG

I. PURPOSE

This memorandum summarizes the September 9 , 2010 conference call between the Environmental Protection Agency (EPA) and industry representatives from the American Petroleum Institute (API). The discussion allowed API an opportunity to inquire about the timeline of the upcoming proposal. The phone conference also allowed EPA to ask questions of API regarding emission sources and potential information API could provide regarding emission

controls.

II. DATE

The phone call took place on September 9 , 2010 from 11 a.m. to 12:30 p .m. via a conference line provided by the American Petroleum Institute.

III. ATTENDEES

The following individu als check ed

- in through the conference line. This does not represent an
extensive list of the Industry Representatives that participated in the call since no formal sign

- in
sheet was available over the phone line.

Industry Representatives

American Petroleum Instit ute : Matt Todd

B ritish P etroleum : Jeffrey A. Adams

Chevron : Clay Fleeberg,

Janet Bounds
ConocoPhillips : Clint Gill

ExxonMobil : Tom Monahan

Marathon Oil : Jenny Yang

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## / R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 25 0  Chapel Hill, North Carolina 2751 4 Telephone: (919)484

- 0222  Fax: (919) 484

- 0122 Shell : George Deeley

U.S. Environmental Protection Agency (EPA/OAQPS /SPPD/CCG )

Bruce Moore

Nick Parsons

Dave Salman

EC/R Incorporated

Heather Brown

Denise Grubert

Karen Marsh

Phil Norwood

IV. SUMMARY OF DISCUSSION

The phone conference was scheduled during a previous meeting with API held on July 21, 2010. The purpose of the phone call was to allow API to ask questions of the process being conducted to determine regulated sources and to allow EPA to gather pertinent information regarding emission control technology. Introductions were aut omatic at time of person calling onto the

conference line. The following is a summary of what was discussed during the call.

After introductions, a question was addressed to Bruce Moore regarding the public meetings held on August 2 in Arlington, TX and o n August 3 in Denver, CO. Bruce responded that the meetings were highly attended by a broad spectrum of stakeholders and good feedback was obtained as a result of the meetings.

API also inquired the result from site visits in Colorado and Wyoming. EPA re sponded the visits were highly productive. The facilities visited provided useful information on co ntrol options f o r vari ous emissions. In particular, it was useful to see firsthand a multi

- well production sites, liquid gathering systems and land farms.

API questioned if methodology previously discussed will change as a result of the meetings and site visits. EPA responded that the same emission sources are still under consideration as well as the same control technologies and work practices. API question ed the current timeline and EPA stated they wanted to have a brief completed in 2 months. T he following points were under

review:

o Emission levels

o Controls

o Cost

- effectiveness

o Scope Limitations.

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## / R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 25 0  Chapel Hill, North Carolina 2751 4 Telephone: (919)484

- 0222  Fax: (919) 484

- 0122 API asked what additional information would be most useful for EPA at this time. EPA responded that costs for control options and composition of the industry, i.e. ratio of small to large businesses, would be useful in the current effort to distinguish small business impacts. EPA

stated the current information for bus iness information data is based on NAICS codes with employee number but EPA is particularly interested in an additional layer of business information if they could provide or point to resources. API questioned what was the threshold

for small business? EPA responded 500 employees or less. API responded that the majority of producers would be considered small business. Questions were asked in relation to who owns the site or number working on a site, i.e. contractors. API than stated their information wo uld be more anecdotal on this topic and not specifically pertinent to the analysis in question. The L asser database was mentioned as possibly having direct information.

Phil Norwood of EC/R raised a question of known gas composition data, specifically for oil wells. Another question involved the difference in emission from gas associated wells versus condensate wells. API responded that there was so little gas in condensa te wells that it becomes difficult to obtain accurate samples.

Another qu estion was raised regarding API’s opinion on current state and local air regulations, particularly in States where site visits were held, i.e. Texas, Colorado, and Wyoming. EPA is

h ighly curious if API feels there are pitfalls in current regulations. API stated it was possible to gather previous comments from the proposed State rules and send to EPA.

API wanted to mentioned difficulties in regulating Offshore Platforms. Space is li mited and the platforms are engineered for specific weight and space. Retrofits are expensive and highly difficult. New sources are easier to incorporate controls within the initial design. API also wanted to point out regional differences. Alaska and Wyom ing have very remote and cold locations that require heat and insulation.

In addition, API stated Leak Detection and Repair (LDAR) is not only LDAR. Many necessary

r ecord s must be kept as well as tags, which add to costs.

EPA mentioned it could consider 111(d) guidelines for States as the Agency has not currently decided on whether it will regulate greenhouse gases. It was also noted the potential for CTG for existing sources in non

- attainment areas.

API pointed out d iscrepancies in definitions in s ubp art KKK. EPA said it would be combining KKK and LLL into one NSPS. API also wanted to point out the difficulty in interpretation the current NESHAPS regulations. It would be easier to separate out into different subparts.

API requested another meeting in October. Another meeting was scheduled for the afternoon of October 12, 2010 at United States Environmental Protection Agency in Research Triangle Park,

North Carolina.