Roy Rakiewicz 2017-04-05 01:51:42
With the inauguration of a new administration that has declared its intent to ease the regulatory burden faced by industry, new environmental regulatory activity for most industries has slowed considerably. Consistent with the regulatory reform theme, on March 2, 2017 the U.S. Environmental Protection Agency announced that it is withdrawing a November 2016 information collection request that required owners and operators in the oil and natural gas industry to provide information on equipment and emissions at existing oil and gas operations. Notwithstanding the withdrawal of the ICR, the oil and gas industry, a key component of Pennsylvania’s industrial base is facing a combination of relatively new and proposed state and federal air quality related rules will likely keep environmental managers in this sector busy in 2017. Summaries of several new and proposed state and federal requirements related to air quality and the oil and gas industry are provided below. Pennsylvania Initiatives Early last year Gov. Tom Wolf announced a plan for reducing methane emissions from Pennsylvania oil and gas operations. On February 4, 2017, the Pennsylvania Department of Environmental Protection published proposed revisions to General Plan Approval and/or General Operating Permit (GP)-5 for new or modified natural gas compression stations, processing plants and transmission stations and proposed GP- 5A for new or modified unconventional Natural gas well site operations and Remote Pigging Stations. Proposed GP-5A is intended to replace existing Exemption No. 38 for new and modified unconventional natural gas well site operations. Conventional natural gas well site operations will not be subject to GP-5A. In addition to proposed GP-5 and GP-5A, DEP also published proposed revisions to Document No. 275-2101-003 “Air Quality Permit Exemptions” and a Technical Support Document for proposed GP-5 and GP-5A. The initial 45 day public comment period was slated to close on March 22, 2017; however, DEP has since announced that the comment period was extended to June 5, 2017. Affected sources have the option to apply for the use an applicable GP in lieu of preparing and submitting a Plan Approval Application to DEP for review and approval. In using a GP, the applicant agrees to abide by the conditions specified in the GP. Because the conditions of the permit are “established” and because the permit has already been through the public review and comment process, the DEP can review and process applications for Gps in an efficient manner (i.e., in as few as 30 days). The GP serves as both a construction and an operating permit. Proposed GP-5 and GP-5A address emissions, applicable requirements and best available technology from 12 “overlapping” operations that can occur at natural gas compression stations, processing plants, transmission stations, unconventional natural gas well site operations and remote pigging stations. GP-5 also addresses stationary natural gas fired combustion turbines and centrifugal compressors while GP-5A also addresses well drilling/hydraulic fracturing, well completions, and wellbore liquids unloading. It is important to note that Gps are “preconstruction” permits. That is, an affected source cannot begin actual construction on an affected facility until the GP has been issued. The preconstruction requirement is important because the proposed GP-5A covers drilling activities. The proposed Gps also each have certain requirements that, as a result of BAT, are more stringent than corresponding applicable federal requirements. Federal Initiatives Not to be outdone, several recent federal rule revisions and initiatives will also impact Pennsylvania oil and gas operations in 2017. 40 CFR Part 60 Subpart OOOOa — Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 Subpart OOOOa was promulgated in June of 2016, but initial reporting for affected facilities is due in 2017. In addition, initial fugitive methane surveys for affected well sites and compressor stations were deferred until June 3, 2017. 40 CFR Part 98 Subpart W — Mandatory Greenhouse Gas Reporting: Petroleum and Natural Gas Systems The EPA finalized amendments to the 40 CFR Part 98 Mandatory Greenhouse Gas Reporting Rule on October 22, 2015, which affected facilities regulated under Subpart W of the rule in the Petroleum and Natural Gas Systems industry. The amendments expanded the scope of the rule by adding two industry segments (e.g., Onshore Petroleum and Natural Gas Gathering and Boosting; and Onshore Natural Gas Transmission Pipelines). The amendments have been in effect since January 1, 2016 and the first report under the revised rule is due in March 2017 for emissions occurring during calendar year 2016. On November 30, 2016, U.S. EPA published a revision to Subpart W to incorporate the Subpart OOOOa leak detection requirements. The revisions will affect companies reporting emissions under Subpart W and, in particular, those companies with well sites or compressor stations subject to fugitive emissions monitoring requirement under Subpart OOOOa. The Subpart W revisions became effective on January 1, 2017. Therefore, Subpart W leak surveys and emissions calculations for calendar year 2017 (due in March 2018) must be conducted in accordance with the new requirements. 40 CFR Part 372 — Toxic Chemical Release Reporting: Community Right to Know On January 6, 2017, the EPA proposed to add natural gas processing facilities to the list of industrial sectors subject to toxic release inventory reporting under 40 CFR Part 372 — Toxic Chemical Release Reporting: Community Right to Know. If finalized as proposed, the TRI reporting requirement will result in the first occasion that many types of data specific to the oil and gas industry become available to the public for review. The comment public comment period for the proposal ended on March 7, 2017. ■ Roy Rakiewicz is senior consultant for All4 Inc.
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