NSPS OOOO (No!)

Joe Leonard Devon Energy

EFOs 22nd Annual Meeting

October 4th, 2013

About Devon

Founded as a private company in 1971

Became a public company in 1988

Has grown from 185 employees in 1981 to 5,000 employees today

Active driller in Oklahoma

NYSE: DVN www.devonenergy.com page 2

Agenda

NSPS OOOO Refresher Affected Facilities

Storage Vessels

Oklahoma Permit By Rules (PBR)

Questions

NYSE: DVN www.devonenergy.com page 3

What is NSPS OOOO?

NSPS New Source Performance Standard

Applies to sources constructed after a certain date 8/23/2011

Technology over time Cheaper Increased availability

NYSE: DVN www.devonenergy.com page 4

NSPS OOOO

Hydraulically Fractured Natural Gas Wells Minimize emissions

Reciprocating Compressors Change rod packing

Centrifugal Compressors Control of wet seal emissions

Pneumatic Controllers No continuous high bleed

The heavy hitters

NYSE: DVN www.devonenergy.com page 5

What is OOOO?

Storage Vessels 6 tons per year (tpy)

NYSE: DVN www.devonenergy.com page 6

NSPS OOOO

Affected Facility

has the potential for VOC emissions equal to or greater than 6 tpy Group 1: 8/23/11 - 4/15/13 Group 2: 4/15/13 Forever

*Note: Determination for G1 tanks must be made by 10/15/13

Compliance

Reduce VOC emissions by 95.0 percent

Group 1: 4/15/15 Group 2: 4/15/14

Storage Vessels - What Everyone Knows

NYSE: DVN www.devonenergy.com page 7

NSPS OOOO

Cover inspections monthly audio, visual and olfactory inspection

Control piping inspection monthly audio, visual and olfactory inspection

Flare/combustor inspection Confirm pilot is lit 15 minute smoke observation Audio, visual and olfactory inspection Check air vent for obstruction Check for liquid reaching the combustor

Storage Vessels The Fine Print Monthly Inspection Requirements

NYSE: DVN www.devonenergy.com page 8

NSPS OOOO

Tank ID with lat/long location

Determination of VOC rate

Deviations

Combustor manufacturer tests

Unsafe to inspect or difficult to inspect maintenance plans

For mobile tanks, records or dates onsite

Closed vent system and cover inspections

Control bypass inspections

Records of inspections, corrective actions taken, manufacturers operating instructions, procedures and maintenance schedules

Records of smoke reading Company, location, company rep, process unit, start time, observation period, accumulated

emissions time, end time

Storage Vessels The Fine Print Recordkeeping & Reporting Requirements

NYSE: DVN www.devonenergy.com page 9

EHS Engineering Guidance

Avoid becoming subject to the fine print! Process changes Reduce production Permit out Etc.

Run Run Run

NYSE: DVN www.devonenergy.com page 10

Permit By Rule

Developed in response to NSPS OOOO

40 tpy VOC PTE

10 tpy single HAP PTE

25 tpy combination HAP PTE

New & Existing Facilities

Nothing special

NYSE: DVN www.devonenergy.com page 11

Permit By Rule

ODEQ Form 100-223 Page 2 Second Section

But Wait!

NYSE: DVN www.devonenergy.com page 12

Permit By Rule

Emissions are less than 6 tpy

Compliance with NSPS OOOO without being subject to the fine print!

What Does Enforceability Mean?

NYSE: DVN www.devonenergy.com page 13

Permit By Rule

Everyone gets what they want EPA gets compliance

Oklahoma gets to support local business

Industry continues to operate

Emissions are lowered

NYSE: DVN www.devonenergy.com page 14

Happily Ever After

NYSE: DVN www.devonenergy.com page 15

Summary

NSPS OOOO Refresher Multiple affected sources Storage vessels may be heaviest hitter

Storage Vessels Groups 1 & 2 Avoid becoming subject to the rule!

Oklahoma PBR 40 tpy limit Enforceability

NYSE: DVN www.devonenergy.com page 16

Thank you

Questions?