1. Update on EPA Oil and Gas Activities Greg Green, Outreach and Information Division, OAQPS

2. Overview ► Background ► New Source Performance Standards ► Control Technique Guidelines ► Voluntary Efforts ► Tribal NSR ► Feedback ► Schedule 2

3. Background ► In January, EPA announced a series of steps it plans to take to address methane and smog-forming VOC emissions from the oil and gas industry ► The goal is to ensure continued, safe and responsible growth in U.S. oil and natural gas production ► Our plans to address methane are part of a comprehensive White House Methane Strategy ► The strategy consists of both regulatory and voluntary approaches ► 2011 EPA promulgated the Indian country minor NSR rule and committed to develop general permits that could include oil and gas extraction 3

4. Overview of NSPS/NESHAP, CTG, and Minor NSR Permitting Rule ► NSPS/NESHAP standards are technology-based standards to meet CAA mandates under Sections 111(d) and 112 ► NSPS and NESHAP are national standards that apply everywhere ► Reduce VOC, HAP and potentially methane emissions ► CTG is intended to provide air agencies with information to assist them in determining RACT ► RACT requirement for VOC and NOx applies to existing sources in moderate (and above) ozone nonattainment areas and the Ozone Transport Region ► Minor NSR rule promulgated to protect air resources in Indian country ► Would apply only to Indian country (i.e., reservation lands, but not allotments and dependent Indian communities) ► Would reduce emissions of VOC and other NSR-regulated pollutants ► Minor source permit must ensure attainment of NAAQS, which affects selection of control requirements 4

5. New Source Performance Standards (NSPS) ► EPA plans to build on our 2012 NSPS for the oil and gas industry to reduce methane emissions and to achieve additional reductions in VOCs ► We are looking at cost-effective, commonsense requirements for new and modified oil and gas sources that are significant emitters of methane and VOCs. ► We are focusing on the sources covered in the five White Papers issued in 2014 for peer review and public comment ► Compressors ► Emissions from completions and ongoing production of hydraulically fractured oil wells ► Leaks ► Liquids unloading ► Pneumatic devices ► We plan to issue a proposal this summer and a final rule in spring 2016 5

6. Control Technique Guidelines (CTGs) ► CTGs provide states guidelines for requiring reasonably available control technology (RACT) to achieve VOC reductions from existing sources in ozone nonattainment areas that are classified as Moderate and above, and in states in the Ozone Transport Region ► Once a final CTG is issued, states with ozone nonattainment areas that are required to implement RACT (areas classified as Moderate and above) and states in the Ozone Transport Region will need to update their State Implementation Plans showing how they will reduce VOC emissions from sources covered by the CTG ► Although not required, states can require RACT (and implement the CTGs) in attainment areas in their states, if they choose to do so ► We intend to identify commonsense requirements for significant emission sources ► We plan to issue the draft CTGs for public review and comment at the same time we issue a proposed NSPS 6

7. Voluntary Efforts ► EPA plans to expand the successful Natural Gas STAR Program by launching a new partnership in collaboration with key stakeholders by the end of this year ► Under the new partnership, EPA plans to enter into voluntary agreements with individual companies that achieve the following: ► Encourage innovative and ambitious commitments with flexible achievement mechanisms ► Provide accountability and transparency for reduction commitments, and ► Track progress toward specific methane emission reduction activities ► EPA is working with the departments of Energy and Transportation and with leading companies, individually or through broader initiatives such as the Downstream Initiative or the One Future Initiative, to develop a program based on robust commitments to reduce methane emissions ► EPA will release a program proposal in spring 2015, and then collect and synthesize feedback in order to launch the new program with founding partners by the end of 2015 7

8. Tribal NSR for Oil and Natural Gas Minor Sources ► Substantial growth in oil and natural gas activity in some parts of Indian country ► No counties in Indian country with oil and natural gas activity have air quality violations ► However, this will likely change depending on which proposed revised ozone standard is adopted ► Situation could be worse than we realize as the tribal air monitoring network is very limited and largely nonexistent ► In areas of poor air quality, concerned for: ► Public health and the environment ► National treasures, such as Dinosaur National Monument ► Permitting of new wells and economic impacts on tribes given existing emissions ► Makes it challenging to permit new emissions in these areas ► Nonattainment designations process and associated air planning can be used to address existing minor sources ► Developing an approach to address the emissions and permitting requirements for source in Indian country 8

9. Feedback ► EPA has been talking with states and tribes to hear how they have managed issues, and to get feedback that will help us as we develop the rule. ► In February, asked states and tribes to nominate themselves to participate in discussions. Eleven states and 8 tribes volunteered. ► Have been meeting to discuss questions, such as: ► Whether states/tribes are, or have considered, regulating the sources identified in the white papers. ► Factors considered in determining whether to regulate them. ► Use of innovative compliance options ► Experiences implementing Control Techniques Guidelines (CTGs) ► Information/features that would be helpful to include in a CTG ► Whether any sources of emissions are particularly suitable to voluntary rather than regulatory action 9

10. Schedule of Rulemaking for these Rules ► EPA is evaluating the feed back and is currently developing proposed rules ► Anticipate proposal of these rules this summer ► Will be offering consultation shortly ► We will also be offering additional consultation after proposal

11. Contact Info ► Gregory Green, Office of Air Quality Planning & Standards, Green.Gregory@epa.gov, 919-541-2769 Green.Gregory@epa.gov ► Chris Stoneman, Office of Air Quality Planning & Standards, Stoneman.chris@epa.gov, 919-541-0823Stoneman.chris@epa.gov ► Bruce Moore, Office of Air Quality Planning & Standards, moore.bruce@epa.gov, 919-541-5460 moore.bruce@epa.gov ► Laura McKelvey, Office of Air Quality Planning & Standards, McKelvey.Laura@epa.gov, 919-541-5497 McKelvey.Laura@epa.gov ► Carey Bylin, Office of Atmospheric Programs, bylin.carey@epa.gov, 202-343-9669 bylin.carey@epa.gov