National Oil and Gas Emissions Committee

National Oil and Gas Emissions Committee

Monthly Meeting Minutes for Thursday, November 13th 2014

Attendees

Roy Huntley, OAQPS, EPA

Jennifer Snyder, OAQPS, EPA

Alex Macpherson, OAQPS, EPA

Lee Riddick, ORD, EPA

Melissa Weitz, OAP, EPA

Anhar Karimjee, OAP, EPA

Alexis McKittrick, OAP, EPA

Carl Young, R6, EPA

Terry Johnson, R6, EPA

Theresa Pella, CenSARA

Tom Moore, WRAP

Regi Oommen, ERG

Mike Pring, ERG

John Grant, Environ

R2: NY (Ona Papageorgiou)

R3: Allegheny County (Tony Sadar), MD (Tim Wallace), WV (Bob Betterton)

R5: MI (Dave Mason), OH (Tom Velalis)

R6: NM (Mike Schneider), OK (Mark Gibbs), TX (Michael Ege)

R7: KS (Lynn Deahl)

R8: CO (Dale Wells), WY (Brian Bohlmann)

Moderator: Mark Gibbs of OK

Agenda

1. Approve minutes of October meeting

2. Tribal area emissions from EPA Minor New Source Review permits – John Grant (Environ)

3. Report on the EPA/States Oil and Gas Emissions Summit – EPA RTP Offices, November 4-5, 2014

Presentations available at: http://www.epa.gov/ttn/chief/oilandgassummit/

4. Formation of Workgroups to address Summit Action Plan goals

5. Possible funding sources for O&G work:

(i) Community-Scale Air Toxics Ambient Monitoring Grants (see attached)

(ii) Regional Applied Research Effort (RARE) Projects:

http://www.epa.gov/sciencematters/december2011/rare.htm

6. Update on EDF/Industry Field Studies

7. O&G training and presentations at the 2015 International Emission Inventory Conference

8. Valedictory comments – Roy Huntley

9. Next meeting Thursday, December 11 at 2:00pm – 3:30pm Eastern, same call in number and confirmation number

The minutes of the October 9th meeting were approved without comment.

John Grant of Environ gave an overview of tribal area emissions based on EPA Minor New Source Review permits. They were able to derive emission estimates for a range of source categories specific to the Fort Berthold Indian Reservation (FBIR) from permit data but a lot of data mining and analysis was necessary. This was supplemented with information from elsewhere about other source categories that they felt would likely be operating but were not reported in the permit. For many of the sources there was 50-70% coverage of operators related to total production in the FBIR. Emissions were typically based on permit limits which often assume 8760 hours/year operation. John noted that small compressor engines (<50 hp) and mobile sources (e.g., drill rigs, frac engines) do not need to be reported under this MNSR program.

Mike Schneider asked what caused the difference in PM emission factors between the Williston Basin and the FBIR on Slide 10. John felt this could be due to different emission factors reported for engines in the two areas but he had not looked into this issue in detail. In response to a question from Mark Gibbs, he said the permits gave sufficient information about the types of engines so the relevant different emission factors could be used. Mark Gibbs also asked how complete was their data mining. John said they looked at permits from a particular operator, then aggregated the data for that operator, then looked at the operator’s % of total field production in the IHS database to identify completeness and to develop representative well site factors.

For future studies access to permit data in digital format rather than having to access paper copies at EPA’s office in Denver would be very helpful. In addition, John also noted that no snapshot in time existed, i.e., it was difficult to identify well starts and which facilities were actually operational during a certain year. Roy Huntley asked whether they assumed 100% burner operation. John replied that they used whatever data was provided by the operators but that they did look at categories for overall reasonability. For example, for casing head gas they didn’t use permit data that 100% was always flared but defaulted to other estimates for the fraction of gas that was flared. Mike Pring asked what format gas composition data was submitted in. This varied by operator: some provided lab reports in supporting documents whereas others did not provide such a level of detail.

Tom Moore asked about the interplay between permit data versus data obtained from surveys of operators in the Williston Basin. John said that where certain source categories were not available in permits these were supplemented by the survey data. Theresa Pella asked what the operator response rate was for the Williston Basin. John couldn’t remember off top of his head but thought it was around 60-70%; more details are in the documentation (link on Slide 14). Mike Schneider asked about the Fuel Heat Value of 1509 Btu/SCF on Slide 8. John said this relatively high value was representative of the Williston Basin where the production tends to be higher in the heavier hydrocarbons.

Mark Gibbs summarized the recent EPA/States Oil & Gas Summit and he encouraged people to look at the presentations which are available at http://www.epa.gov/ttn/chief/oilandgassummit/. Mark noted that there was good participation by EPA GHGRP and GHGEI staff and Theresa Pella echoed Mark’s comments. She especially looked forward to continued participation by the ORD and GHG groups but thought engagement with the mobile group may be more challenging going forward. Tom Moore appreciated senior EPA staff and mangers from different EPA offices being engaged on the complex issue of oil and gas emissions. Further such meetings will be needed to make progress. Roy Huntley appreciated the attendance of non-EPA participants and noted that the presence of a facilitator was very helpful.

Mark Gibbs discussed forming workgroups to address the goals in the Summit Action Plan goals. He was not concerned about having a complex structure of subcommittees but rather ensuing that at least a few people would lead the efforts to make sure work was getting done and that efforts between offices were being coordinated. He said that volunteers could contact him after the call.

The first item on the Action Plan was responding to the urgent need to update the non-road model and to compare between non-road model and tool estimates for oil and gas emissions. Jennifer Snyder will coordinate with OTAQ and Theresa Pella encouraged her to let us know if help is needed from states on MJO’s on this topic.

A major goal in the Action Plan is for OAQPS and OAP to develop a crosswalk between data fields and emission factors to identify differences between the criteria and GHG inventories. This crosswalk can be used to guide tool improvements. Tom Moore commented that we shouldn’t expect to stay with the particular data structure of separate databases for ever. He noted the problem of producer survey fatigue from repetitive reporting (e.g., to the EPA regional office in Denver, to the GHGRP and then to a survey by WRAP) and he suggested ultimately combining reporting requirements to unify efforts. He also noted the problem where small individual operators are reporting to the GHGRP because they aren’t above the 25,000 ton reporting threshold.

Mark briefly mentioned proposed improvements to the tool (as opposed to improving activity data or gas composition data) which had been discussed in the July meeting. Roy Huntley confirmed that the EPA budget for implementing such improvements is still unknown. Theresa Pella emphasized closely aligning efforts on the OAQPS/OAP crosswalk with looking to best use Subpart W activity data. This may also help with prioritizing improvements to the tool when there is a limited budget available. Mike Pring cautioned about making complex tool improvements when there will be no data to populate fields.

Anhar Karimjee of the GHGRP said that while 2014 activity data will not be available until next year they would be happy to set up webinar to explain the data fields they are collecting. Anahar said there are some explanations for the differences between the GHG numbers produced by the tool, the GHGRP and the national GHG inventory, and that there are efforts underway to better align things such as emission factors. Roy Huntley said that Jenifer Snyder and Melissa Weitz will need to work together on going forward to analyze and understand differences between the inventories which is a priority for EPA management. Tom Moore felt there should be a frank assessment of whether the current databases and tools will be adequate for key future tasks, e.g., estimating future coincident reductions in criteria pollutants, GHG’s and HAPs.

Another topic in the Summit Action Plan was reaching out to states with limited resources and Mark Gibbs said he would reach out to Cindy Beeler at EPA Region 8 to lead this effort. Theresa Pella and Tom Moore are listed as leads on compiling existing state oil and gas regulations in one place, such as the Three State Data Warehouse. This could be part of a larger information repository containing webinars and results of oil and gas work and studies that can help states build capacity. Several people have volunteered to help with the effort to get better gas composition data, such as making use of low hanging fruit in state permit files. The general opinion from the summit was that regulations for oil well completions is a gap that exists/needs to be addressed. The problem that states cannot impose more stringent rules than EPA on NOx emissions from nonroad engines may be an important issue for states to comment on when the proposed Ozone NAAQS comes out.

Two possible funding sources for Oil & Gas work were introduced and briefly discussed: Community-Scale Air Toxics Ambient Monitoring Grants and Regional Applied Research Effort Projects.

Ona Papageorgiou asked about the GHGRP proposal to require API numbers to be reported. Alexis Mckittrick said that proposal will likely be signed soon and she would send a link to the prepublication copy out to the committee as soon as it becomes available.

Mark Gibbs has spoken to Ramon Alvarex at EDF about the UT-Austin Phase 2 Production Site Study. This is expected to come out around Thanksgiving. The Industry/EDF midstream studies will not be published until 2015. CSU had called OK about one such study where their work showed Oklahoma to be an (upper) outlier with regard to number of compressor stations in the state. Mark wondered about the accuracy of making projections based on national averages of oil and gas facility and equipment distributions when the midstream “plumbing” can vary significantly between basins.

Tom Moore and Regi Oomen are the chairs for the O&G session at the 2015 International EI conference. They are soliciting abstracts (due end of November) and would like to have a panel session with representatives from EPA, states, and industry. Mark said that after the EPA/States Summit the next logical step is to involve industry in efforts to improve O&G inventories and he urged that API be invited to participate. The conference will also be a useful check-in for progress on the Summit Action Plan.

Jennifer Snyder said that a half day has been scheduled for oil & gas training at the conference and she asked for input from the committee on what this should cover. In addition to training on using the tool, Mark wondered whether there would be resources for the training on OOOO recently given by Ron Truelove of Trinity to several states. For the EI conference, preference might be for material on oil and gas operations versus regulatory applicability. Ona Papageorgiou suggested going through each of the main processes at an oil and gas production site for two hours then spending two hours on using the tool. This would help people new to oil & gas emissions get up to speed with what they will need to do for their 2104 NEI submission. Lynn Deahl suggested using a small database as the example during tool training in order to get people quickly set up for the hands-on training.

Roy Huntley gave some brief remarks on the occasion of his upcoming retirement.

Next meeting is Thursday, December 11 at 2:00pm - 3:30pm Eastern.