RE:Oil and Natural Gas Regulatory Review Oil and Natural Gas Regulatory Review Oil and Natural Gas Regulatory Review --EPA and Environmental Group EPA and Environmental Group EPA and Environmental Group 

Initial Teleconference

Bruce Pendery Bruce Pendery to: Bruce Moore 07/27/2010 01:00 PM

History: This message has been replied to and forwarded .

Dear Mr. Moore,

I joined the call today but did not offer any comments . But two issues I

want to point out for your consideration are the following :

--I think it will be important to address emissions from drill rigs . At

least in Wyoming drill rigs are often the largest source of nitrogen oxide

emissions in an oil and gas field, at least during well field development .

You touched on this at least somewhat , but an issue with drill rigs has been

that they are considered mobile sources , and thus subject to EPA regulation

and not state regulation. In Wyoming this has lead to great confusion and

uncertainty as to how or if to regulate this significant emissions source .

It would be helpful if in your rulemaking this issue could be addressed and

rectified. It would be desirable if states were given explicit regulatory

authority, or lacking that EPA stepped in with explicit regulation of

emissions from drill rigs. Also I note this. In at least some gas fields

in Wyoming (specifically the Pinedale Anticline ), I think it is debatable

whether drill rigs are really "mobile" in any meaningful way in the context

of the "one year rule." On the Pinedale Anticline as many as 32 wells are

being drilled on a single well pad, meaning a drill rig may not "move" more

than about 25 yards between well bores for extended periods of time .

--As you probably know, the Wyoming Department of Wyoming Environmental

Quality regulates minor sources of emissions , including from oil and gas

production facilities (well pads) through its "presumptive BACT" program.

On August 1 the latest revision to the Wyoming oil and gas presumptive BACT

measures will go into effect. These measures (they are not considered

rules, but effectively are regulations) address many of the sources of

emissions you are concerned about--pneumatic devices, condensate tanks, well

completions, etc. This may of interest to you.

Thank you for considering this input .

Bruce Pendery

Wyoming Outdoor Council

444 East 800 North

Logan, UT 84321

(435)-752-2111

This message may be protected by the attorney -client privelege. If you

recieve it by mistake please notify me .

The Wyoming Outdoor Council has worked to protect Wyoming 's land and

wildlife since 1967. We need your help. Please join us today at

http://www.wyomingoutdoorcouncil.org.
-----Original Message-----

From: Moore.Bruce@epamail.epa.gov [mailto:Moore.Bruce@epamail.epa.gov] 

Sent: Monday, July 26, 2010 5:03 PM

To: Jeremy Nichols; Mike Eisenfeld; Amy Mall; Vickie Patton; Ramon Alvarez;

Joanne Spalding; Bruce Hamilton; Deborah Goldberg; Gwen Lachelt; Erik

Schlenker-Goodrich; Joe Osborne; Jim Black; jim@bradburycounsel.com;

elise@cecenviro.org; charlie@cecenviro.org; mfreeman@earthjustice.org;

libby59@sbcglobal.net; ahedges@meic.org; josh@sanjuancitizens.org;

roger.singer@sierraclub.org; brad.mohrmann@sierraclub.org;

rfflorez@juno.com; frank@wccongress.org; laurie@wyomingoutdoorcouncil.org;

bruce@wyomingoutdoorcouncil.org; Deborah300@sbcglobal.net;

bruce@earthworksaction.org

Cc: Tsirigotis.Peter@epamail.epa.gov; Lassiter.Penny@epamail.epa.gov;

Hustvedt.Ken@epamail.epa.gov; Branning.Amy@epamail.epa.gov;

Davis.Alison@epamail.epa.gov

Subject: Oil and Natural Gas Regulatory Review -- EPA and Environmental

Group Initial Teleconference

Attached are an agenda and one-pager to be used in our call scheduled for

12:00 to 2:00 pm Eastern on Tuesday, July 27th. The call may not last the

entire two hours, but I wanted to allow sufficient time for discussion . The

call-in number will be 919-541-1958. Please do not call early -- if you

receive an error tone or message, just hang up and try again in a minute or

two.

You will notice that the agenda provides an opportunity for topics to be

added based on interest. We will take suggestions for additional items

following the roll-call.

I believe it is important to involve stakeholders on all sides early enough

in the review process to enable meaningful input . The primary purpose of

this call is to initiate contact with the interested environmental groups

and to introduce you to our review in progress .

There may be follow-up calls in the future, based on need.

Thanks in advance for your cooperation ,

Bruce

(See attached file: Oil & Gas Sector Regulatory Review Update

07-27-10.doc)(See attached file: Agenda - EPA-Environmental Group Call on

Oil and Gas 27Jul10.doc)

Bruce Moore

Senior Technical Advisor, Oil and Natural Gas Sector

Sector Policies and Programs Division

Office of Air Quality Planning and Standards U .S. Environmental Protection

Agency (E143-01) Research Triangle Park, NC 27711

Phone (919) 541-5460 Fax (919) 541-0246

"moore.bruce@epa.gov"