# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

TO: Bruce Moore

, EPA/OAQPS/SPPD/CCG

FROM: Bradley Nelson, EC/R, Inc.

DATE: November 29 , 201 1

SUBJECT: Summary of the November 29

, 20 11

, Teleconference with the Independent

Petroleum Association of America (IPAA) and the U.S. Environmental Protection Agency to D iscuss the Proposed Oil & Gas NSPS/NESHAP

I. INTRODUCTION

IPAA requested this meeting with EPA to discuss questions on the proposed Oil and Gas NSPS (40 CFR Part 60, subparts KKK, LLL, and OOOO) and NESHAP (40 CFR Part 63, subpart s HH

and HHH ). This meeting summary will be available in the docket for this rulemaking (Docket

ID No. EPA

- HQ

- OAR

- 20 1 0

- 0 505 ). The proposed rule for the oil and natural gas sector wa s published in the Federal Register on August 23, 20 11 (7 6 FR 52738 ).

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Bruce Moore Greg Nizich

David Cozzie

IPAA

Lee Fuller , IPAA Matt Kellogg , IPAA Jim Collins, IPAA Consultant

Jim Erb

– IPAA C onsultant

Brian Woodard

– Chesapeake Energy Corp Grover Campbell

– Chesapeake Energy Corp2

EC/R Incorporated

D avid Hendricks Bradley Nelson

III. SUMMARY OF DISCUSSION

Bruce Moore opened the meeting by stating that the proposed rules are currently in the comment period and EPA could answer clarifying questions from the group, but could not provide any responses to comments on the proposed rules.

IPAA stated that they planned to submit their comments on the proposed rules tomorrow, but wanted to introduce themselves to EPA. IPAA is an industry group that represents independent oil producers from large publically traded companies to small independent producers. IPAA

st ated that 80% of oil wells are marginal wells that produce less than 15 barrels per day and 2/3 of the natural gas wells are also marginal wells . These wells represent 12

- 13% of the oil produced in the U.S.

IPAA stated that this meeting will focus on t wo specific issues: green completions and vapor recovery for storage vessels. They noted that they also support the comments submitted by the

Interstate Natural Gas Association of America ( INGAA ) and the American Petroleum Institute (API).

IPAA stated that many of the independent producer wells are vertical well s that have a different emission profile in comparison to horizontal wells. The group does not believe that EPA took

the smaller emissions from these vertical wells into consideration during the development of the proposed rules. IPAA also stated that they also had concerns with the applicability thresholds for storage vessels. They stated that the throughput for storage vessels at some marginal wells may exceed the threshold for a short period due to modifications to the well

. Because the storage vessel exceeded the threshold level, it would become an affected source under the proposed rules, even though the average production level over a longer period is below the threshold level.

IPAA stat ed they could provide contacts to discuss these issues further

.

IPAA also mentioned that older storage vessels may be less airtight than when new. Installing a vapor recovery system on an older storage vessel may draw air into the storage vessel with the potential of creating an explosive gas mixture.

EPA stated that they have not heard these concerns in other meetings or comments and are open to suggestions from the industry group. EPA asked the group to provide specific

recommendations on the issues t hat they raised. They noted that April 3, 2011 was the deadline for the final rule and they needed to develop a draft package by mid

- January to meet this

deadline.