nadarko Petroleum Corporaton August 21, 2017
P.O. Box 173779 * Denver,TCeolelophroadnoe: 8702201-972-387-67090020
I H H I t l l rnrnmum PBrolmrn Corporation
VIA ELECTRONIC MAIL traylor,patrick@epa,gov
Patrick Traylor Deputy Assistant Administrator Office of Enforcement and Compliance Assurance U.S. Environmental Protection Agency U.S. EPA Headquarters - Mail Code 2201A 1200 Pennsylvania Avenue NW Washington, DC 20460
Re: EPA Roundtable on Clean Air Act Compliance Assurance A ctivities in the Oil and Gas Sector - Anadarko Petroleum Corporation Participation Request
Dear Mr. Traylor:
Through recent agency correspondence with trade associations in the Western Region of the United States, Anadarko Petroleum Corporation (Anadarko) is aware of the U.S. Environmental Protection Agency's (EPA's) intention to convene a roundtable consisting of representatives of the oil and natural gas industry and state regulatory agencies in order to discuss industry concerns, including the recent EPA and state Clean Air Act (CAA) compliance assurance activities in the oil and natural gas sector. Anadarko respectfully requests to participate as an industry representative on the EPA Roundtable Clean Air Act Compliance Assurance Activities in the Oil and Gas Sector.
Anadarko is one of the United States' largest independent oil and natural gas production companies with approximately 1.7 billion BOE of proved reserves worldwide, including onshore assets in Colorado, Texas, Utah, and Wyoming, and offshore assets in the Gulf of Mexico. Anadarko also has a significant midstream business and operates gas processing plants in Colorado, Wyoming, and Texas. These operations occur on a mix of private, federal, and Tribal lands.
Uniquely situated as an operator in both the upstream and midstream sectors of the oil and natural gas industry, we are well-positioned to provide meaningful insight, perspective, and information to the roundtable. Able to address a broad range of topics such as industry-regulator relationships, enforcement, technological advancements able to drive rule changes, Anadarko is eager to share its knowledge and experience. We wish to develop opportunities for productive partnerships targeting environmental protection while ensuring responsible domestic oil and gas production. Anadarko has been subject to several CAA 114 requests in recent years pertaining to the leak detection and repair (LDAR) regulations at Part 60, Subparts KKK, OOOO, and Part 60 Subpart HH.
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Patrick Traylor August 21, 2017 Page 2
Anadarko has participated in numerous federal rulemakings, such as source aggregation, the regional consistency rule, CTGs, Subpart OOOOa and the ozone NAQQS, in all submitting comments and participating in meetings with EPA representatives. Additionally, Anadarko has been at the forefront of state air quality regulatory reform efforts targeting the oil and gas sector. In 2014, Anadarko actively participated in the State of Colorado's methane and volatile organic compound (VOC) rulemaking. We are currently participating in an EPA-based regulatory reform effort in Colorado focused on further methane and VOC emissions reduction. Through these experiences, Anadarko has gained valuable experience and insight concerning the unique issues associated with crafting and implementing effective and feasible air quality regulations for the oil and natural gas sector and the relationships between industry and the regulatory agencies.
Anadarko is committed to the responsible production, and long-term viability, of our domestic oil and natural gas resources in a manner that also ensures protection of human health and the environment. With great appreciation, Anadarko welcomes this rare opportunity that EPA has presented to foster meaningful dialogue and enhanced communication amongst stakeholders.
We assure you that Anadarko's participation will be productive and collaborative to craft solutions to these pressing and complicated issues.
Sincerely,
f /
Tfevid McBride VP USE
cc: Julia A. Jones, Counsel Korby Bracken, Director TISE E&P Onshore Bill Grygar, Director HSE Midstream Jennifer Biever, Hogan Lovells US LLP
Sierra Club v. EPA 18cv3472 NDCA
Tiers 8&9
ED 002061 00176849-00002