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/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514

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 individuals checked-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 Institute: Matt Todd

British Petroleum: 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 250  Chapel Hill, North Carolina 27514

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 automatic 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 on 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 responded the visits 

were highly productive. The facilities visited provided useful information on control options for

various 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 questioned the current timeline and EPA 

stated they wanted to have a brief completed in 2 months. The 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 250  Chapel Hill, North Carolina 27514

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 business 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 would be 

more anecdotal on this topic and not specifically pertinent to the analysis in question. The Lasser 

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 condensate wells that it becomes 

difficult to obtain accurate samples. 

Another question 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 

highly 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 limited 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 Wyoming 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 

records 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 discrepancies in definitions in subpart 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.