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NSPS OOOOa - Looking Forward
- 1. NSPS OOOOa – Looking Forward Presented By John A. McGreevy November 2, 2016 Prepared For
- 2. The Past ► U.S. EPA’s understanding of the oil and natural gas industry has significantly increased ▪ April 2015 multi-million dollar settlement ▪ September 2015 Compliance Alert ► Enforcement initiative focused on “Energy Extraction” has focused on oil and natural gas ▪ In Ohio, West Virginia, and Pennsylvania there have been 551 inspections in the past 5 years, and 113 formal enforcement actions within the past 5 years* ▪ This is a 20% enforcement rate *U.S. EPA’s ECHO system, October 21, 2016 2
- 3. The Present ► Regulatory changes ▪ NSPS OOOO ▪ NSPS OOOOa ▪ Source determination ► Information requests / data gathering ▪ ICR in two phases ▪ Used to develop rules for existing sources ► Continuation of the enforcement initiative 3
- 4. The Future ► Nobody can precisely predict the future ► What can we be thinking about going forward? ▪ Compliance timelines ▪ Social cost of methane ▪ Design and maintenance requirements ▪ Leak detection technology ▪ Ozone transport and RACT rules 4
- 5. Compliance timelines ► NSPS OOOOa Leak Detection Timelines ▪ Federal timelines for fugitive leak detection and repair programs do not always dovetail with state requirements ▪ Examples: o OOOOa – initial survey within 60 days o Ohio GP 12 – initial survey within 90 days o OOOOa – initial attempt at repair within 30 days o Ohio GP 12 – initial attempt at repair within 5 days ▪ Potential to comply with one standard but not the other 5
- 6. The social cost of methane ► U.S. EPA performed a “Costs and Benefits” review on the most recent version of NSPS OOOOa ▪ Incorporated the “social cost of methane” looking at reductions by 2020 and by 2025 ▪ Ranges between $550 and $3,800 per metric ton ▪ These costs were used to justify the federal LDAR programs in the new rule, and underlie the RACT recommendations in the new CTG document ► Where will these costs be used next? 6
- 7. Design and maintenance requirements ► NSPS OOOOa requires closed vent system design to be certified by a professional engineer ▪ This requirement drives company internal policies and procedures ▪ Includes feasibility of controlling emissions under all anticipated scenarios, including IP rates ► General duty clause for NSPS ▪ 40 CFR 60.11(d) – “…owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions.” ► Documentation is key to avoiding potential issues 7
- 8. Leak detection technology ► Current technologies can be expensive and / or time consuming ▪ Specific performance criteria and work practices in rule ► NSPS OOOOa allows a demonstration of “equivalency” ▪ The process is ambiguous, taken directly from the Clean Air Act ▪ May allow future flexibility ► The Interstate Technology and Regulatory Council (ITRC) ▪ Developing consensus criteria for assessing different methane detection technologies ▪ This is an active field of research and quickly evolving 8
- 9. The Ozone Transport Region and RACT rules ► U.S. EPA officially published a new Control Techniques Guidelines (CTG) document for the oil and gas industry ▪ Limitations and recommendations directly from OOOOa ▪ Applies to existing sources in some ozone non-attainment areas and states in the OTR ▪ 2 years for states to revise their rules to incorporate these requirements – RACT rules ► The OTR currently includes Pennsylvania ▪ Several OTR states submitted a petition to U.S. EPA on December 9, 2013 requesting the addition of several more states, including Ohio ▪ This petition is still pending, no action has been taken as of yet 9
- 10. Thank you ► I appreciate your attention, and look forward to your questions and comments 10