EPA

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EPA

Moderator : Scott Fraser August 23, 2011 3:00 p.m. E T

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?

Op erator: 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 pr ess star then the number one on your telephone keypad. If you would like withdraw your question p ress 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 pres ent 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 than k 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 propo sal essentially includes the

first Federal air standards o n wells that are hydraulically fracked.EPA

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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 co

bene fit the rule also achieves significant reductions in methane emissions

from these

– from the se 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 underpinn ing of th is 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 coul d 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 fir st 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 t ons 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 facili ties 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'sEPA

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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.

Thi s 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 ea ch 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 sourc e 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 faciliti es, 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 met hane 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 pneu matics 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 producti on facilities, as far as (permitting) that would result from theEPA

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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

reg ulation.

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

– tha t

– 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 De nver, 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 NS PS 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. An d 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 t he 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.EPA

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Operator: Again, if you would like to ask a question press star then t he 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 C ampbell : 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 ac tivities that will have to take place and we're asking folks to give us their insight during theseEPA

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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 do n'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 o ff 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 l ogistics

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 (Alliso n 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 noti ce 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 Ha egele: 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 complet ions 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 withEPA

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the proposal date

– today, but then the effective date is not until

– 60 days

after it's fi nalized.

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 Tsirig otis : 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: A gain, 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 (Q uad 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 valv e?

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 fac ility 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

...EPA

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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 a t 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 the m 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 theEPA

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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? Y ou 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 comment s on these things, but as you're thinking through

these reach out a nd talk to us about it because we

– we realize that this is a

p retty complicated industry and we want

– again we again to get these things as accurate as possible.

And if there's things t hat 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 befo re 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 contingenc ies 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.

S o 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 ma ximally 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.EPA

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Operator: Again if you'd like to ask a qu estion 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 req uests 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 surprising ly 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.EPA

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

telephone k eypad. 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 busines ses. 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. Tha t 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 (interagenc y) 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 d o 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 informat ion 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 w e 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 tim e frame between now and February 28,

and a 60 day, two months taken up with a comment period, does EPA believeEPA

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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 req uests 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 informati on 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 com pletions 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 emission s 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 w ell 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.

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

over to Mr. Scott Fraser

.EPA

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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 offi ce 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 wi ll wrap it up and thank you for joining.

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

END