September 11, 2018
The EPA has proposed amendments to the 2016 New Source Performance Standards for the oil and gas industry. The plan will make it easier for the oil and gas industry to comply with certain requirements, and is expected to save the industry up to approximately $484 million in regulatory costs from 2019 – 2025, or $75 million annually. The following three issues were reconsidered as a result of objections received by the EPA: (1) fugitive emissions requirements, (2) well site pneumatic pump standards, and (3) requirements for certification of closed vent systems by a professional engineer. In addition to these issues, the EPA proposed amendments to clarify and streamline the implementation of the rule. Lastly, the EPA proposed technical corrections and amendments in the final rule.
Summary of Proposed Changes
Fugitive Emission Requirements
The proposed amendment would modify the monitoring and repair schedules for fugitive emissions by extending timelines and lowering frequencies of schedules for specified sites. The proposal also clarifies requirements for conducting the surveys using emerging technologies. Additionally, the amendments would establish alternative fugitive emissions standards based on requirements established by certain states, including Texas.
Well Site Pneumatic Pump Standards
The EPA is proposing to amend a requirement that a professional engineer certify when it is technically infeasible to route emissions from a pneumatic pump to a control device or a process. This amendment would allow either a professional engineer or in-house engineer with appropriate expertise to make these certifications. The proposal also seeks to amend the definition of “greenfield sites” as it relates to those requirements, and expand the technical in-feasibility provision to include both “greenfield” (new) and “non-greenfield” (existing) well sites.
Requirement for Certification of Closed Vent Systems by a Professional Engineer
The proposed amendment would allow in-house engineers with appropriate expertise, in addition to professional engineers, to evaluate designs of closed vent systems and certify that their design and capacity are sufficient to route emissions to a control device from centrifugal compressor wet seal fluid degassing systems, reciprocating compressors, pneumatic pumps and storage vessels.
Definition of a “Well Site”
The proposed amendment would change the definition of “well site” such that third party equipment located downstream of the custody meter assembly and saltwater disposal facilities would no longer be included as part of the well site.
A full, detailed list of the changes can be found in the proposed amendment document here.
The EPA will be taking comments to the proposed rule for 60 days after the proposal is published in the Federal Register, and a public hearing will be held in Denver. You can find a summary of the proposal and more information on how to submit a comment here.
If you have any further questions, please contact Waid Environmental.