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NSPS OOOOa - Looking Forward
- 1. NSPS OOOOa āLooking Forward Presented By John A. McGreevy November 2, 2016 Prepared For
- 2. The Past āŗ U.S.EPAās understanding of the oil and natural gas industry has significantly increased āŖ April 2015 multi-million dollar settlement āŖ September 2015 Compliance Alert āŗ Enforcement initiative focused on āEnergy Extractionā has focused on oil and natural gas āŖ 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* āŖ This is a 20% enforcement rate *U.S. EPAās ECHO system, October 21, 2016 2
- 3. The Present āŗ Regulatorychanges āŖ NSPS OOOO āŖ NSPS OOOOa āŖ Source determination āŗ Information requests / data gathering āŖ ICR in two phases āŖ Used to develop rules for existing sources āŗ Continuation of the enforcement initiative 3
- 4. The Future āŗ Nobodycan precisely predict the future āŗ What can we be thinking about going forward? āŖ Compliance timelines āŖ Social cost of methane āŖ Design and maintenance requirements āŖ Leak detection technology āŖ Ozone transport and RACT rules 4
- 5. Compliance timelines āŗ NSPSOOOOa Leak Detection Timelines āŖ Federal timelines for fugitive leak detection and repair programs do not always dovetail with state requirements āŖ Examples: o OOOOa ā initial survey within 60 days o Ohio GP 12 ā initial survey within 90 days o OOOOa ā initial attempt at repair within 30 days o Ohio GP 12 ā initial attempt at repair within 5 days āŖ Potential to comply with one standard but not the other 5
- 6. The social costof methane āŗ U.S. EPA performed a āCosts and Benefitsā review on the most recent version of NSPS OOOOa āŖ Incorporated the āsocial cost of methaneā looking at reductions by 2020 and by 2025 āŖ Ranges between $550 and $3,800 per metric ton āŖ These costs were used to justify the federal LDAR programs in the new rule, and underlie the RACT recommendations in the new CTG document āŗ Where will these costs be used next? 6
- 7. Design and maintenancerequirements āŗ NSPS OOOOa requires closed vent system design to be certified by a professional engineer āŖ This requirement drives company internal policies and procedures āŖ Includes feasibility of controlling emissions under all anticipated scenarios, including IP rates āŗ General duty clause for NSPS āŖ 40 CFR 60.11(d) ā āā¦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.ā āŗ Documentation is key to avoiding potential issues 7
- 8. Leak detection technology āŗCurrent technologies can be expensive and / or time consuming āŖ Specific performance criteria and work practices in rule āŗ NSPS OOOOa allows a demonstration of āequivalencyā āŖ The process is ambiguous, taken directly from the Clean Air Act āŖ May allow future flexibility āŗ The Interstate Technology and Regulatory Council (ITRC) āŖ Developing consensus criteria for assessing different methane detection technologies āŖ This is an active field of research and quickly evolving 8
- 9. The Ozone TransportRegion and RACT rules āŗ U.S. EPA officially published a new Control Techniques Guidelines (CTG) document for the oil and gas industry āŖ Limitations and recommendations directly from OOOOa āŖ Applies to existing sources in some ozone non-attainment areas and states in the OTR āŖ 2 years for states to revise their rules to incorporate these requirements ā RACT rules āŗ The OTR currently includes Pennsylvania āŖ Several OTR states submitted a petition to U.S. EPA on December 9, 2013 requesting the addition of several more states, including Ohio āŖ This petition is still pending, no action has been taken as of yet 9
- 10. Thank you āŗ Iappreciate your attention, and look forward to your questions and comments 10