Document dQnKM3kryZdeb1zz1GVMrYEYR

To: Dravis, Samantha[dravis.samantha@epa.gov] From: NDPC Sent: Fri 3/31/2017 8:41:59 PM Subject: NDPC Letter to EPA Administrator Scott Pruitt NDPC LTR to Scott Pruitt 3.31.2017.pdf ND vs EPA.pdf 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00007732-00001 V n H T 11 1 > A K * > ' f A PETROLEUM ' v i: ; . E**irniioitil Protection Agency Mr. Scott Pruitt, Administrator Mail Code 21221T 1200 fomsylwmit Aw, NW Washington. DC 2W60 Dear Mr Me e.Veii 5 *,< i-'iKMiiiiC-iiiMl Protection Agency. I w*. s*i5ftlt - '' ' ' ' (NDl'i i .r i*. h..ii u ii A h , to tell yoc '> < ('i . i,'. .* . ;r . i >' . .. m., V! , - iters. ` *i.l. i - - , - - r AkmjifA kAmmiswttf-mgCiemAk Mi (CAAiSeeiim 114- ' > ' `t, f n ' . ( , U ' 'Mr Dakota. KTA's style and process ww often contrary t the North Dakota Department of Health's (NODoH) aternttive approach r< < .- r -n, It it ;"< >' !..r.% 'ii',': i i >'<*, t Action, Not* Dakota:: . w . :t final decree, even though MDDoH had participated folly in monte ofEPA driven negotiations wtdi the operator. The Me** IMtoi* %aa%m4b.wjs wwSfMmMK fmM We respectfully najacm, consistent with yur w,.-. - - . - #' i, it lnTf M,r h 2t, 201? Exettfove Order. # romvbwng' j%&rgp t*oepe&8&H& ubu Gcvtutmic utowhi, tftai y#u gtfwipfy ftii% fc.rA & titii&rtftit urjra ** Acirtii Dakota to ieiiiii whether they are consistent w ristratkm's approach to cftvwonmentai protection ana rnmmtm.' we also ask tfiiti you seriously cwttfer EPA's adoption of the NDDoH apfwoadt to Clea* At Act mftxmmmt M'i wurtapprov/ . . , > . r . ' . i ...... `Wi lu.rtj M: ,, ' i . .('., - tf - . f , ectings wire<mc ; 1 f.u -etheEPASecti , ) M . ; -.<i - ...I I 'A - .. e ' . ; w ,.V i xs .11 *iw - .. L . . . - ,! compliance plus (above oito! reguhttKms) in oe-tkir*I f*e time r|air4 by EPA to negotiate settlement w tth one N1 > opemor. ,J< *' ' i P . nntli r, * ... Ki >. t> <!,. 'r. ' ,. worn* ! nu to mNentu iiee iirrf ado^ rsMss tlim, iimxtif fceoefil the eaviroiioiei*. Heat* can m omu any fiiesiioits yrn may have. We weieeiise a* to travel to Washington, DC ifyou feel it wmi-td he teiefcM. to discuss this with you and would be wililie ni eoiisMeratioii. ScRHor Cory Candner few Cramer 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00007732-00002 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00007732-00003 NORTH DAKOTA "FIND & FIX" Embrace compliance, prevention and innovation for future efficiencies industry-wide. Through this process, regulators and industry work together to identify the issue, find solutions, and fix the issue, resulting in Day 1 compliance that quickly benefits the environment. "SUE OR SETTLE" Emphasis is on penalties and compliance through intimidation. This method embraces bureaucracy and expensive legal pursuits that forces compliance through intimidation rather than focusing on problem-solving. Action is also done one company at a time, meaning very little to no benefit to the environment during the process. PROCESS DURATION & PARTICIPANTS 10 MONTHS working with Industry to identify solutions & an agreement issued Oct. 2016. Meanwhile, companies were voluntarily inspecting and modifying equipment. I I I 2016 2016 2016 1"" `"I rpT " to resolve 1 case with 6 still pending. 3 STATE EMPLOYEES including 2 from Dept, of Health and 1 from Attorney General's Office. 30 COMPANIES producing 93% of ND's oil and the North Dakota Petroleum Council participated in finding solutions. including 5 EPA Attorneys, 2 Dept, of Justice Attorneys and 5 EPA scientists (MPAMY that produces about 2.5% of North Dakota's oil had its case resolved. X130 130 INDUSTRY EMPLOYEES participated in the Task Force, consolidating time, effort and expertise. COST IN TIME AND MONEY of documentation, plus more than 10,000 data points of information requested and filed. 3,000* MANHOURS spent by 30 companies for industry-wide standard. $255,000 to $616,000 in estimated industry employee time. $4.i MILLION in equipment inspection and modification. $ in industry employee time and contractor fees for one company. $29,200 in estimated government employee time for industry-wide plan. $186,900 and $5 in estimated federal employee time alone, plus thousands for mileage and travel. RESULTS 19 CONSENT DECREES signed, covering 69% of ND's oil production & affecting 7500 wells. FUTURE COMPLIANCE Prevention and even new, leak proof equipment were created. CONCLUSION, North Dakota's inclusive approach consolidates time and effort, allowing for collaborative education, new technologies and designs for enhanced compliance industry-wide that are beneficial early in the process and well into the future. 17cv1906 Sierra Club v. EPA - 6/22 Production signed, with 170 wells modified into compliance. spent on fines and mitigation projects that do not assist in resolving issue. le U.S, EPA's approach addresses the issue one company at a time at a pace three times slower than the "Find and Fix" approach. This means more resources are depleted with very little return to the environment. ED 001523 00007733-00001