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EPA Finalizes Changes to NSPS That Will Affect Oil & Gas Industry - Monday, May 16, 2016


EPA Finalizes Changes to NSPS That Will Affect Oil & Gas Industry

The Environmental Protection Agency (EPA) published a final rule on May 12, 2016 which involves changes to the New Source Performance Standards (NSPS) for the oil and gas industry by setting standards for both methane and VOC’s for certain equipment, processes, and activities on affected sites. A primary component of the new standard, referred to as "NSPS OOOOa”, is adding methane as a regulated pollutant with the goal of reducing emissions from the oil and gas sector by 40-45% by 2025. The EPA has indicated that methane is the second most prevalent greenhouse gas, and oil and gas operations have been found to be the largest industrial contributor of methane emissions in the country. The new standard will affect a multitude of source types, but the primary focus of this document is the proposed rule’s specific requirements for oil and gas well sites with regards to methane. At this time, only facilities which were constructed, modified, or reconstructed after September 18, 2015 are subject to this final rule. However, EPA also issued an Information Collection Request (ICR) that will require companies to begin providing information on existing oil and gas sites which will be utilized to develop future regulations to reduce methane emissions from those sources as well.

Fugitive emissions can occur where connections are not properly fitted, gaskets are not adequately sealed, etc., and EPA acknowledges that this is a significant source of methane and VOC emissions. EPA will accept the use of "optical gas imaging (OGI)” technology to conduct surveys of methane and VOC emissions which will provide visible confirmation of a leak using infrared cameras. The proposed required schedule to conduct these surveys is shown below:

§ Owners and operators of new oil and gas well sites will have one year from the date of the finalized rule or within 60 days of startup to conduct an initial leaks survey (whichever is later)

§ For modified sites, within 30 days of the modification

§ After the first survey, leak monitoring will be conducted twice a year

Any leaks identified during the surveys will require repair within 30 days of discovery. In the event that the repair would require shutting down production, the repair can be delayed until the next scheduled shutdown. Additional equipment subject to this monitoring will include separators, storage tanks, line heaters, and dehydrators. The fugitive emission monitoring requirements will not apply to non-producing well sites where only a wellhead protector is present. However, low production wells (<15 barrels per day) which were originally proposed to be exempt from these requirements, are subject to the final rule.

This legislation will certainly present new challenges for oil and gas well operators from both a compliance and cost standpoint. T. Baker Smith, LLC (TBS) is in the process of developing innovative approaches to providing efficient and cost effective optimal gas imagery to Oil & Gas clients which includes utilizing our Unmanned Aerial Vehicles (UAV) to detect fugitive emissions. Additionally, TBS provides regulatory compliance, monitoring, and permitting for our clients’ facilities and operations.

Additional information regarding the newly finalized rule and the Information Collection Request for existing sites can be found on the EPA Website or contact the TBS Environmental group at (985) 223-9256.



 

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