EPA

Scott Fraser:

08-23-11/3:00 p.m. ET

Confirmation # 93594065

Page 1

EPA

Moderator: Scott Fraser

August 23, 2011

3:00 p.m. ET

Operator: Good afternoon. My name is (Hope) and I will be your conference operator 

today. At this time, I would like to welcome everyone to the proposed new air 

rules ...

Male: Hello?

Operator: For oil and natural gas conference call. All lines have been placed on mute to 

prevent any background noise. After the speakers' remarks there will be a 

question and answer session. If you would like to ask a question during this 

time, simply press star then the number one on your telephone keypad. If you 

would like withdraw your question press the pound key. Thank you.

Mr. Scott Fraser you may begin your conference.

Scott Fraser: Thank you. Hello everybody. This is Scott Fraser. I'm with the office of 

public engagement here in D.C. and as you can imagine we're enjoying some 

of nature's fun today so we want to give folks a little extra time to call in due 

to the earthquake here that happened shortly.

But we're up and running and ready to go with this topic for today, proposed 

air rule for oil and natural gas. Presenting is Peter Tsirigotis and he's the 

Director of the Sector Policies and Programs Division at the Office of Air 

Quality, Planning, and Standards of EPA and he's going to present for about 

10 minutes or so and after that we're going to pause for questions.

Today's topic can be found online at EPA.gov/air quality/oilandgas. So with 

that, I'm going to turn it over to Peter.

Peter Tsirigotis: Thank you Scott. I'd like to thank everybody for joining too. I'll just give a 

broad brush of what's in the regulation. Essentially we – the agency proposed 

a regulation July 28 that essentially places standards on a number of sources 

in the oil and gas industry overall. And this proposal essentially includes the 

first Federal air standards on wells that are hydraulically fracked.
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And essentially the standards of design to reduce what's called volatile organic 

compounds (VOCs) and air toxics including benzene. As an ancillary cobenefit the rule also achieves significant reductions in methane emissions 

from these – from these wells – from these fracked wells. And methane is a 

potent greenhouse gas more than 20 times more potent than carbon dioxide.

The standards, and I'll get into this a little – a little later, I have as an 

underpinning of them, sort of looking at costs, as well as looking at reduction. 

So one of the underpinnings of this rule is to make sure that the reductions are 

cost effective. Also another underpinning of this rule is to (inaudible) 

technologies that are available technologies and as a result we – the agency 

want to do a pretty extensive economic analysis looking at the costs and 

looking at the impacts and when one factors in potential savings associated 

with capturing of – of this gas, one could essentially also have a rule that has 

some net savings overall.

Essentially when we look at the whole industry, we see it as sort of split up 

into about four components. One component is the production. And those are 

the wells. Another component is the processing facilities. A third component 

is the transmission and storage facilities. And a fourth component is the 

overall distribution.

What these rules that I'm going to describe focus on primarily are the first 

three components which are the production, the processing, the transmission 

and the storage. What – when one looks at the emissions associated with this

– with this activity what the – what the EPA estimates is that annually there's 

about 2.2 million tons of VOC emissions and about 130,000 tons of air toxic 

emissions, as well as 16 million tons of methane emissions annually.

These emissions are – are emitted by a variety of sources. Most notably 

they're emitted by a – roughly about one million facilities that actually 

produce the oil and natural gas, these gas wells. There's about 600 processing 

plants. There's about 3,000 transmission and compression stations. And 

overall we estimate somewhere around one and a half million miles of gas 

pipeline. 

The regulations that the EPA is proposing are basically two kinds of 

regulations. One set of regulations focuses on the criteria pollutants and that's 

the VOC portion. Another set of regulations focuses on the (inner) toxic 

emissions. And – and – and there's different authorities under the clean air act 

that come to (bear) in the context of the criteria pollutants.

We rely on what's called the New Source Performance Standard Program and 

we set standards for new and modified sources for the air toxics rule. The 

agency sets standards initially which we set a number of years back for what's 
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call maximum achievement control technology, MAC. And then eight years 

after that, the agencies required to do a technology review and a residual risk 

review.

This proposed action is that technology review and residual risk review. In –

in – in large part the way the – the – the rules are designed, obviously because 

with putting them out in (tandem) where the concept is to have these rules be 

complimentary with each other. There's a different focus on each one of these 

rules. Obviously one is criteria, the other one is air toxics.

But at the end of the day the Texas controls that get put in place are very 

similar for both air toxics and criteria. The new source performance standards 

in large part focus on the production which is the gas wells. The air toxics 

rules in large part focus on the processing and transmission right along 

(inaudible). Yes, so for those two types of facilities the NSPS and the MAC 

work in tandem.

Essentially just to give you an idea of the types of controls required by each 

program. What each program looks at. Starting with the NSPS, the program 

looks at well completions in the context of the production facilities and 

regulates the well completions. There's also regulations that cover 

compressors, pneumatic controllers, and storage vessels. 

And ultimately the – ultimately the kinds of reductions that we're looking at 

with the NSPS program is in the case of the production facilities, on a case by 

case basis the kinds of controls that we'd be looking at these well completions 

generally get somewhere in the order of 95 percent VOC reduction. It's worth 

noting that they also result in about 90 percent recovery of product. 

So out of that 95 percent reduction, 90 percent of it is – is – is the recovery of 

product. The rule also recognizes that in some cases product cannot be 

recovered and looks at (flaring) of the solution in those cases. The kinds of 

reductions that we're looking at overall in the context of the well completions 

are somewhere in the vicinity of about a half a million tons of reductions per 

year.

You can compare that to what I mentioned initially is 2.2 million tons of 

VOCs emitted by the whole industry. The methane reductions that we project 

are somewhere in the vicinity of about 3.3 million tons per year compared to 

the (60) million tons per year that we estimate are being emitted. The other 

controls that we're looking at in the context of compressors and pneumatics 

and processing plants and storage vessels add up to about 40,000 tons per year 

of VOC reduction and about 100,000 tons per year of methane reduction.

The other thing that is proposed in this rule is how to treat facilities, especially 

gas production facilities, as far as (permitting) that would result from the 
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requirements that get put in place by this rule. What we're proposing is that 

the – the NSPS requirements would not in themselves create the need for a 

Title V permit. We are proposing that we exempt these well completions 

from the Title V applicability. And again as it relates specifically to these 

NSPS controls.

The – and then I'm finishing up, the last thing worth mentioning is I pretty 

quickly broad brush covered what in general we're doing in the rule. But 

because there's a number of first things that the agency is doing in the context 

of this rule, there's a number of places throughout the preamble of this 

proposal where the agency solicits comment on a number of aspects of this 

regulation.

Everywhere from the kinds of technologies and the kinds of methodologies 

that the agency has used as a technical (inaudible) to certain policy decisions 

that the agency is proposing as a result of this rule. The public comment 

period that – that – that's in place at 60 days after publication, the rule has not 

yet been published so the 60 days will begin after the rule gets published in 

the Federal Register. 

And the agency's planning on holding three public hearings. One in Dallas, 

one in Denver, and one in Pittsburgh. And those – the specific locations and 

the specific times would be – will be announced. The – it's also worth noting 

that these regulations were under what's called the consent decree. 

We got (inaudible) to do both the NSPS and the (ototoxic) regulations because 

the agency was late in doing these rules. And as a result, we entered into the 

consent decree on when the rules would be proposed and when they would be 

final. We've completed step one of that consent decree and issued the 

proposals. And step two of that consent decree had of issuing the finals 

February 28 of 2012. That's it, Scott from me. 

Scott Fraser: OK. Thank you. I just wanted folks to know before we turn this over to 

questions that we do have a large group of stakeholders as participants on this 

call, a wide variety. We have health and environmental organizations. 

We have industry and business. We have state and local governments. So 

just keep that in mind when you're asking your questions. And with that I'll 

turn that back over to the operator to tell you how to begin asking questions.

Operator: At this time if you would like to ask a question press star then the number one 

on your telephone keypad. We'll pause for just a moment to compile the Q 

and A roster.

Peter Tsirigotis: Oh, one thing to mention I just heard that actually got published today, the 

rule in the Federal Register. So the 60 day clock begins from today.
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Operator: Again, if you would like to ask a question press star then the number one on 

your telephone keypad. Your first question comes from the line of Grover 

Campbell with Chesapeake Energy.

Grover Campbell: Yes, I was just wondering Section 60.5365 states that compliance with 

(inaudible) is not required until after it's published as final rule. But the 

sources, like NSPS, are affected sources today. So my question is do this 

industry have to start putting in low bleed pneumatic valves and tanks that 

comply with the rule as they're built or can we wait until the rule is published?

Peter Tsirigotis: (Inaudible), the requirement would be in place 60 days after publication of the 

final. So those devices would need to be on 60 days after the final.

Grover Campbell: OK. Does that – so we don't have to start installing all ...

Peter Tsirigotis: No, the – the trigger that you might be referring to in the context of the 

proposed rule, and this applies to the New Source Performance Standards, the 

NSPS, is you – you – you are affected as of the date of the proposal. So if you

are a new source as of the date of the proposal, you will need to put controls in 

60 days after the rule goes by. 

So these – the proposed date is not a date of when controls get put in place, as 

much as a date from which applicability gets determined.

Grover Campbell: Well, that – that – that still sounds like if – if, let's say we have to put in new –

we have to put in new pneumatic controllers, for instance, all the time. So if 

we put one in tomorrow that was a (hide) lead then after the rule goes in affect 

60 days after publication, then we'd have to come back and replace it with a 

low bleed.

Peter Tsirigotis: If – if – if it's a source that's covered under the NSPS, I see your question right 

now and I don't the exact answer to that. I think the answer might be yes. 

That if you have replaced it now, it might be prudent for you to go ahead and 

replace it with a low bleed and be done with it. That would be my advice.

Grover Campbell: Yes, I mean serious--

Peter Tsirigotis: (Inaudible).

Grover Campbell: It's kind of setting us up for non-compliance because these things are 

happening right now.

Peter Tsirigotis: And actually that's one of the elements of the rules that we call out in the 

proposal to see – because we realize there's a number of activities that will 

have to take place and we're asking folks to give us their insight during these 
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60 days so we can have this as sort of, it's harmonious if you will, an 

induction program if possible.

And – and -and some of these issues I'm sure will be popping up between 

proposal and final that we might not have absolutely captured in the proposal. 

And that was the idea of (facilitating) comments on these elements. 

So what I'd advise you to do is if you identify sort of specific problems 

associated, or vagueness associated with the rule, please call that out and –

and – and we will obviously not only address it but our interest is to try to 

make this program as – as – as implementable as possible. The one thing I 

mentioned after my (inaudible), I don't know if it actually got out on the 

waves is I heard that actually that the rule got published today in the Federal 

Register. So the 60 day comment period begins as of today.

Grover Campbell: OK. I have a couple of more other questions but I'll get off for now.

Peter Tsirigotis: Thank you.

Operator: Your next question – our next question comes on the line of Greg Haegele, the 

Sierra Club. Greg, your line is open.

Greg Haegele: I'm here. Thank you. Sorry. I had it on mute. I have a very basic logistics 

question. Which is I know we have the three public hearings coming up. I 

don't – I have not seen a timing notice on those. Can you all advise on or give 

a rough guess on when we might being – have those?

(Allison Davis): Hi, my name is (Allison Davis). I work here at (OAQPS) and we're looking at 

the last week of September. You should see a notice go out fairly quickly. 

We were just waiting to make sure that we had all of contracts for the 

locations sewn up. But – and – and look for the notice to confirm this but I 

believe the dates are September 27, 28, and 29. They will be in Pittsburgh, in 

Denver, and in Arlington, Texas in that order.

Greg Haegele: That was Pittsburgh, Denver, and Arlington in that order.

(Allison Davis): Yes.

Greg Haegele: Thank you.

Operator: Your next question comes from the line of Jeff Adams with BP.

Jeff Adams: Yes. Kind of following up on (Grover's) question earlier about applicability. 

There are, as you said, hydraulic fracturing emissions, or green completions 

are required by this rule. And that's a one time type event. It comes, you do 

it, and it's gone. This rule would make that an effective source starting with 
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the proposal date – today, but then the effective date is not until – 60 days 

after it's finalized.

I'm assuming that because I couldn't do it before it was effective that that's not 

a non-compliance issue. That it would only be required for those completions 

that were done after the effective date. Is that a correct statement?

Peter Tsirigotis: Yes, that is correct statement. There is no requirement to do the green 

completions that the requirements of the rules associated with the completions 

before the 60 days after the final rule. You are right.

Jeff Adams: OK. Thank you.

Operator: Again, if you'd like to ask a question press star then the number one on your 

telephone keypad. Your next question comes from the line of (Lynn Reed) 

with (ONEOK).

(Lynn Reed): Hello. I have another question of applicability and compliance. It's – after

this rule is final and after the 60 days and you've got an existing (Triple K) 

process unit and you make a modification to it. Let's say you add some 

valves, then, I'm not sure I understand the timing as to how – at what point do 

you become subject to (Quad O) and when are your Sub Part A letters like the 

first – the first letter would be a potential change to an existing source is –

would that be applicable here or would it just be noticed after the start of 

construction, after installation of a new valve?

Peter Tsirigotis: Hi (Lynn). This is – the answer to this one is over my head but I will turn to 

(Bruce) and see if he can provide some insights to you.

Male: The requirements of the old Sub Part KKK which is the leak detection and 

repair provisions for gas processing plants is what you're referring to. And if 

you had an existing gas processing plant the new NSPS would not affect that 

gas processing plant. That's a plant wide requirement as opposed to many of 

the other requirements in our NSPS which are equipments specifics, like a 

storage vessel or a – a – a compressor.

Now if you were to modify, you would have to meet the modification 

requirement to call the whole gas processing – processing plant a modified 

plant in order for the old to trigger the NSPS for that existing gas processing 

plant. 

Peter Tsirigotis: Does that help you (Lynn)? The – there – what – what I gather from (Bruce) 

is that there is no automatic trigger in your case 60 days after the rule goes 

final. It depends on if the facility as a whole triggers modification and 

therefore becomes a modified facility. Or if you have a new facility that has –

that fits the new definition as of the date of the proposal ...
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(Bruce): I'd like to clarify too that the requirements of Sub Part KKK as written would 

only apply to those facilities that are not new sources. So those requirements 

don't change. In other words, we're changing slightly the requirements for the 

new sources. But those under Sub Part (Quad O) would be a total different set 

of facilities than the older, existing KKK facilities.

(Lynn Reed): So if you modified a gas plant, then would you still be under (Triple K) or 

would you be under (Quad O) for that gas plan?

(Bruce): If you if your change – if that – if your change at the facility triggered 

modification under the general provisions in the definitions of Sub Part 60, 

then you would then be a modified source and be subject to the new (Quad O).

(Lynn Reed): OK. At what point do you have to meet (Quad O)? Would it, you know, we 

do these reports showing that you've added valves and if it was enough to 

trigger a modification then – then you would know it at the end of the six 

month period. Are you supposed to know it on the day the valve goes in and 

so that you can start some clock for you Sub Part A letters?

(Male): (Lynn) I would turn you to the general provisions in this rule. We don't tackle 

the timing of when one – what – what – when one meets the requirements 

after one is called a modified unit. So I would point you to the general 

provisions that are already out there. 

If – if – if more clarity, if – if you would find more clarity in this specific rule 

on these topics, again, I'd encourage you to give us a comment and ask for that 

clarity. That would be very helpful to us to see if – again our interest is to try 

to make this rule as (inaudible) and implementable as possible. So if there's 

places where some further clarity will help, please identify those. 

And I don't know if this is going to be one of them or not. Because this 

particular issue, we have relied on the general provisions or so. If that doesn't 

provide the clarity in your particular case, we're more than happy to structure 

it in this (inaudible) of rules.

(Lynn Reed): Thank you.

Operator: You have a follow up question from the line of Grover Campbell with 

Chesapeake Energy.

Grover Campbell: Hi. Thanks. Yes, my question regards the definition of gas well. I realize we 

probably have time to work on this now because of the answer you gave Jeff 

Adams on when completions are affected. But, as I understand it, the 

requirements on completions only affect gas wells or gas well heads. But the 
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definition is gas well means a well, the principle production of which at the 

mouth of the well's gas. 

My question is that's a little vague. If you could give us a little bit more 

guidance on what that means, so for instance, should we put the gas and oil 

any oil or (inaudible) production on a barrel of oil equipment comparison or a 

(V2U) comparison? You know for regular wells it's not a big deal. You 

pretty well know what a gas well is and what an oil well is. But on the new 

hydraulically fractured wells, some of those produce a lot of condensate or oil 

in addition to gas.

Peter Tsirigotis: That's a very good point and one that I think falls into that previous category 

will – us working together and getting a better sense of clarity of how best we 

can structure the applicability requirements with help. And – and feel free to 

not only give us comments on these things, but as you're thinking through 

these reach out and talk to us about it because we – we realize that this is a 

pretty complicated industry and we want – again we again to get these things 

as accurate as possible.

And if there's things that you guys do in this industry routinely for other 

reasons that would help us be as clear as possible about the applicability while 

minimizing burdens that would be a wonderful outcome. And – and – and 

again this one of the places where there's a number of elements that we're 

soliciting comment on how best to do it. But that's a very good question that 

you raised.

Grover Campbell: Is this an area where – are you going to take some questions and give 

feedback before the comment period – or, I guess before the final rule is out?

Peter Tsirigotis: Officially, the agency probably will not give generally in most rules we do not 

sort of give some reactions officially between proposal and final. But we –

we have numerous meetings with all kinds of contingencies that have 

information to give us during these 60 days. So it's not only the written word 

that you supply to us, but also meetings and information where we can ask 

questions and get more clarity could be helpful and obviously we docket all of 

these.

So what I'd suggest is if – if – if it would be helpful to have even prior to your 

written comments some kind of a session where we can hear exactly the issue 

that you're concerned about and ask a few questions. That – that's what we 

would find the most maximally helpful to come to the right outcome. But do 

not expect that we would sort of tell you oh yes we agree with you or we don't 

agree with you. That is reserved for February 28.

Grover Campbell: OK, thanks.
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Operator: Again if you'd like to ask a question press star then the number one on your 

telephone keypad. Again, if you'd like to ask a question press star then the 

number one. Your next question comes from the line of (Robert Sindilos) of 

Chevron Corporation.

(Robert Sindilos): Yes. Hi. Good afternoon. Given the complexity that we've been discussing 

and that there's evidence in the rule as we review it and today's (inaudible) 

that you all who are in the room from EPA can discuss this. What's your 

attitude about the inevitable extensions requests that are being prepared as we 

speak opposed to the comment date and to the final rule date which we do 

understand is part of the consent decree.

Peter Tsirigotis: Yes, you know, obviously we're in these situations. This is not the first time 

we're in this kind of a situation that we're dealing with a rule that's under 

consent decree. And what the agency does is tries to move as aggressively 

and assertively forward as possible realizing that in some cases some time 

might be need.

What we do is we wait for the inevitable extensions as you mentioned and we 

evaluate them based on the articulation of the need. And one thing I would 

ask you, which I ask everybody, when we're dealing with consent decrees 

where time is very important is to be very clear about articulating why the 

extra time is needed.

Many times, and I can't underscore the many, we get requests that are very 

open ended. And if though the requestor might have a very specific concern 

in mind, a lot of times that's not articulated in the request and – and – and 

many times from our perspective we don't see the justification for an 

extension based on that general statement.

So if there's any encouragement I'd give you, if you request something like 

this is be specific and keeping in mind a court ordered – again it's a court 

ordered consent decree that we have be as aggressive as you can in the sense 

of what time you would request of us. And we just go from there. We take 

these very seriously even when we are under consent decree. But we take 

consent decrees very seriously.

(Robert Sindilos): Thank. I – we appreciate that.

Operator: Your next question comes from the line of Ross Gould with Environmental 

Advocates of New York.

Ross Gould: Good afternoon. Actually my question surprisingly is similar to the one from 

Chevron. Probably the first time we've ever been on the same page. 

Male: (Inaudible), so my answer stands, it's the same.
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Operator: Again, if you'd like to ask a question press star then the number one on your 

telephone keypad. You have a follow up question from the line of Jeff Adams

with BP.

Jeff Adams: Yes, this also has to do with extension requests. Because of some of the 

thresholds on the NSPS for tanks, this rule's going to pull in a great number of 

small businesses. Have – has – my understanding is that EPA has not done a 

small business review on this rule. Has EPA done consideration of the timing 

that's going to need – be needed by OMB in the small business administration 

as well as DOE in reviewing this rule because of the very broad impact this 

rule will have on independent oil producers which are predominantly small 

businesses?

Peter Tsirigotis: The agency, and you can see this in the proposal, goes through a process with 

every regulation to see if there's a, I don't know the exact term of art, but 

essentially of this proportion of impact on small businesses is the result of 

regulation. And – and – and for a number of rules we determine that it – it – it 

does or it does not follow the rules.

In the case of this rule, the agency determined that it did not have a 

disproportionate impact on small businesses. And such we did not institute –

we did not go through the process that would be associated with a finding that 

the agency did have such an impact. That said, this – this regulation as many 

regulations goes in through agency review when we do go through the OMB 

process and OMB sort of shares that (interagency) review.

And unless I'm mistaken the small business administration is part of that 

(interagency) review. So whether the agency believe there's a 

disproportionately impact on small businesses or not for any rule my 

understanding, my experience has been any rule that (SPA) has been 

interested in evaluating and participating in they've been free to do so. And 

the other thing that I'd like to mention to you is if you – if you look through 

our information and – and – and you think that the information would point 

you to a different place than where the agency was pointed to based on either 

the information that you see there or there's additional information that you 

have, please let us know. 

We want to try to have as much information backing up this rule and one of 

the things that we're hopeful – we've gotten quite a bit of before the proposal 

but we know we're going to get after the proposal is data and information. So 

I – I'd really encourage you to share with us any information that you see that 

poses some alarm to you right along with the reasons why.

Male: Was the only having the six month time frame between now and February 28, 

and a 60 day, two months taken up with a comment period, does EPA believe 
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that they're going to have enough time to truly be able to give a reasoned 

response to all the comments it expects including the 57 different requests for 

comments that EPA has in the preamble and still be able to get the rule text 

revised through the (inner) agency or through the EPA review process and 

then the OMB (interagency) review process.

Peter Tsirigotis: The quick answer is at this point yes. Because we would not be having – we 

wouldn't have done what we've done up to now. Obviously the agency 

believes that this is something that could be very credibly done. But there is a 

comment period, and we recognize that there may be new information that 

comes about that we have to deal with.

We – we – this is not an absolute answer today. But I can tell you based on 

what we have in front of us the answer is yes at this point. You might want to 

ask us that question maybe a few months later but at this point the answer is 

definitely yes.

Operator: Again if you'd like to ask a question press star then the number one on your 

telephone keypad. Your next question comes from the line of Bruce Gantner

with Conoco Phillips.

Bruce Gantner: Yes, I had a question. A lot of your regulations seems to be VOC driven and 

I'm curious whether the agency has given thought as to how this applies to the 

expense of the amount of cold bed methane wells that are being developed 

and are the requirements for green completions as well as the pneumatics 

going to apply cold bed methane and other wells that are low in VOC content?

(Male): That's certainly a valid question. We did raise for comment in the proposal 

the question about whether the VOC content of the emissions from the coal 

bed methane wells would warrant having them subject to the rule. And 

similarly you, the point you made about the pneumatic devices that are driven 

by the gas coming from those wells would then have a, you know, similar 

VOC content as the well gas produced.

So that's certainly a valid comment. I would urge you to respond to the – to 

the request for comment on that point in the proposed rule and offer any 

suggestions you might have on what the applicability or how it should be 

spelled out.

Peter Tsirigotis: As well as information that would allow us to look at whether it meets the test 

of cost effectiveness and other things. Any information you have would be 

very useful. But as Bruce said we've actually called out the specific point.

Operator: There are no further questions at this time. I would now like to turn the floor 

over to Mr. Scott Fraser.
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Scott Fraser: Well thank you I'd like to thank Peter Tsirigotis and the rest of the folks in the 

policies and programs division and the office of quality and standards. If you 

do have a follow up that was not able to be answered today I'd like to leave 

my e-mail address. It's fraser.scott@epa.gov. We did have a recording of 

today's session that can be available as well. And with that we will wrap it up 

and thank you for joining.

Operator: This concludes today conference call. You may now disconnect.

END