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/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM 

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

FROM: Bradley Nelson, EC/R, Inc.

DATE: November 29, 2011

SUBJECT: Summary of the November 29, 2011, Teleconference with the Independent 

Petroleum Association of America (IPAA) and the U.S. Environmental Protection 

Agency to Discuss 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, subparts HH

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

ID No. EPA-HQ-OAR-2010-0505). The proposed rule for the oil and natural gas sector was 

published in the Federal Register on August 23, 2011 (76 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 Consultant

Brian Woodard – Chesapeake Energy Corp

Grover Campbell – Chesapeake Energy Corp
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EC/R Incorporated

David 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 

stated 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 two 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 wells 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 stated 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 that 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.