American Oil and Gas Reporter - April 2018 - 101

there is a more pragmatic way to go
about doing whatever needs to be done,"
Fuller promises.
A statement by American Petroleum
Institute President and Chief Executive
Officer Jack Gerard responding to the
exclusion process says the organization
"expects the (Commerce) Department
will acknowledge various market realities
and take into consideration the complex
supply chains of the U.S. oil and natural
gas industry, and the need for specialty
steel not available domestically for many
of its projects."
A letter sent by IPAA to the White
House prior to the presidential proclamations imposing the tariffs points out
that as much as 30 percent of the surface,
intermediate and completion tubing used
in oil and gas production facilities "simply
is not made in the United States and
must be imported."
That letter asked the government to
exclude line pipe and OCTG from any
tariffs and instead rely on anti-dumping
and countervailing duty orders to address

any demonstrated abuses of the line pipe
and OCTG markets. The letter notes there
already are 26 anti-dumping and countervailing duty orders for line pipe and
14 for OCTG, "demonstrating active federal oversight of this market."
Fuller also references a study released
in May 2017 by API, the Association of
Oil Pipe Lines and several other midstream
associations that found 77 percent of the
steel used in line pipe was imported in
2015-16 in the form of finished pipe,
cut-to-length plate and plate coil, or steel
slabs. The study also showed that 55 percent of OCTG consumed those two years
was imported.
"We are searching for answers at this
point," Fuller concludes.
Unknown Impact
Imposition of a tariff doesn't mean
imported OCTG can't be bought, Fuller
emphasizes. "It just means you pay the
tariff. So then it is a question of availability," he allows.
He says IPAA heard anecdotal reports

that a number of countries that produced
specialty OCTG began to cut back on
volumes when the Section 232 process
was announced, likely fearing the United
States might impose quotas instead of
tariffs, which would have left them without
a market for their products.
"I know that as soon as the 232 investigation was announced, domestic steel
companies started raising their prices,"
Fuller continues. "And from what we
have heard, I also would say the market
already was tight for many of these resources.
"There is going to be an impact, no
matter what," he concludes. "There is
going to be a tariff on foreign steel and
the domestic industry is raising its prices,
so there is going to be a cost impact. The
question is: How much of your project is
pipe? If it is 10 percent of the cost and
the tariff increases the steel price by 25
percent, it raises the overall cost by 2.5
percent. But if steel is 50 percent of the
cost . . ."
r

EPA Making Changes To NSPS Rules
WASHINGTON-In a pair of regulatory
actions, the U.S. Environmental Protection
Agency has finalized amendments for
requirements in the 2016 oil and natural
gas New Source Performance Standards,
and is proposing to withdraw the control
techniques guidelines (CTG). The agency
estimates the latter move would save the
industry at least $14 million in regulatory
compliance costs from 2021 to 2035.
"The technical amendments to the
2016 oil and gas NSPS are meant to alleviate targeted regulatory compliance issues
faced by affected sources," says EPA
Office of Air and Radiation Assistant Administrator Bill Wehrum. "While this action addresses an immediate need, it does
not deter the ongoing work at the agency
to assess the 2016 rule as a whole, including whether it is prudent or necessary
to directly regulate methane."
Wehrum adds EPA sees the proposed
CTG withdrawal as necessary to provide
regulatory certainty to one of the largest
sectors of the U.S. economy, while avoiding unnecessary compliance costs to both
covered entities and the states. The guidelines provide recommendations for certain
states and areas that are required to
address smog-forming volatile organic
compound emissions from covered sources
as part of state implementation plans for
meeting national standards for groundlevel ozone.
The agency is amending what it de-

scribes as two narrow provisions of the
NSPS to address aspects of its fugitive
emissions requirements that pose significant and immediate compliance concerns.
They are:
* A requirement that leaking components be repaired during unplanned or
emergency shutdowns; and
* Monitoring survey requirements for
well sites on the Alaskan North Slope.
The American Petroleum Institute says
it welcomes EPA's technical modifications
to its OOOOa rule and the proposal to
withdraw CTG, two actions that it predicts
will provide regulatory certainty for the
oil and gas industry.
"We are hopeful EPA makes additional
improvements to ensure that its rules are
science-based and cost-effective," says
Howard Feldman, API's senior director
of regulatory and scientific affairs. "Ozone
concentrations and methane emissions
are down significantly, and air quality
continues to improve thanks in part to
increased use of domestic natural gas
and industry investments in advancing
technology."
NSPS Changes
EPA says it is finalizing specific amendments to the fugitive emissions requirements rather than staying them based on
public comments and information received
in response to a June proposed stay. According to the agency, the revisions were

published and became effective in the
March 12 Federal Register, with a document citation of 83 FR 10628.
Although the agency amended the
NSPS to remove requirements that sources
of fugitive emissions be repaired during
unscheduled or emergency shutdowns,
it says operators still are required to
complete needed repairs during the next
scheduled compressor station or well
shutdown, well shut in, after a planned
vent blowdown or within two years,
whichever is earlier.
The 2016 NSPS required owners and
operators to monitor and repair leaks from
equipment at well sites and compressor
stations. Under the rule, leak repairs found
during monitoring surveys were required
to be repaired within 30 days unless doing
so was technically infeasible; required a
vent blowdown, a compressor station or
well shutdown or shut in, or if it would be
unsafe to repair while the unit was operating,
EPA describes. In those cases, repairs were
required at the next such event, including
unscheduled or emergency shutdowns, or
within two years, whichever came first.
Since issuing the rule, EPA says, it
has received feedback that requiring repairs
during unscheduled or emergency shutdowns may lead to gas supply disruptions,
safety issues, or increased emissions from
venting or flaring that would be necessary
if equipment were depressurized or blown
down before repairs began.
APRIL 2018 101



American Oil and Gas Reporter - April 2018

Table of Contents for the Digital Edition of American Oil and Gas Reporter - April 2018

Contents
American Oil and Gas Reporter - April 2018 - 1
American Oil and Gas Reporter - April 2018 - 1
American Oil and Gas Reporter - April 2018 - 2
American Oil and Gas Reporter - April 2018 - Contents
American Oil and Gas Reporter - April 2018 - 4
American Oil and Gas Reporter - April 2018 - 5
American Oil and Gas Reporter - April 2018 - 6
American Oil and Gas Reporter - April 2018 - 7
American Oil and Gas Reporter - April 2018 - 8
American Oil and Gas Reporter - April 2018 - 9
American Oil and Gas Reporter - April 2018 - 10
American Oil and Gas Reporter - April 2018 - 11
American Oil and Gas Reporter - April 2018 - 12
American Oil and Gas Reporter - April 2018 - 13
American Oil and Gas Reporter - April 2018 - 14
American Oil and Gas Reporter - April 2018 - 15
American Oil and Gas Reporter - April 2018 - 16
American Oil and Gas Reporter - April 2018 - 17
American Oil and Gas Reporter - April 2018 - 18
American Oil and Gas Reporter - April 2018 - 19
American Oil and Gas Reporter - April 2018 - 20
American Oil and Gas Reporter - April 2018 - 21
American Oil and Gas Reporter - April 2018 - 22
American Oil and Gas Reporter - April 2018 - 23
American Oil and Gas Reporter - April 2018 - 24
American Oil and Gas Reporter - April 2018 - 25
American Oil and Gas Reporter - April 2018 - 26
American Oil and Gas Reporter - April 2018 - 27
American Oil and Gas Reporter - April 2018 - 28
American Oil and Gas Reporter - April 2018 - 29
American Oil and Gas Reporter - April 2018 - 30
American Oil and Gas Reporter - April 2018 - 31
American Oil and Gas Reporter - April 2018 - 32
American Oil and Gas Reporter - April 2018 - 33
American Oil and Gas Reporter - April 2018 - 34
American Oil and Gas Reporter - April 2018 - 35
American Oil and Gas Reporter - April 2018 - 36
American Oil and Gas Reporter - April 2018 - 37
American Oil and Gas Reporter - April 2018 - 38
American Oil and Gas Reporter - April 2018 - 39
American Oil and Gas Reporter - April 2018 - 40
American Oil and Gas Reporter - April 2018 - 41
American Oil and Gas Reporter - April 2018 - 42
American Oil and Gas Reporter - April 2018 - 43
American Oil and Gas Reporter - April 2018 - 44
American Oil and Gas Reporter - April 2018 - 45
American Oil and Gas Reporter - April 2018 - 46
American Oil and Gas Reporter - April 2018 - 47
American Oil and Gas Reporter - April 2018 - 48
American Oil and Gas Reporter - April 2018 - 49
American Oil and Gas Reporter - April 2018 - 50
American Oil and Gas Reporter - April 2018 - 50A
American Oil and Gas Reporter - April 2018 - 50B
American Oil and Gas Reporter - April 2018 - 50C
American Oil and Gas Reporter - April 2018 - 50D
American Oil and Gas Reporter - April 2018 - 51
American Oil and Gas Reporter - April 2018 - 52
American Oil and Gas Reporter - April 2018 - 53
American Oil and Gas Reporter - April 2018 - 54
American Oil and Gas Reporter - April 2018 - 55
American Oil and Gas Reporter - April 2018 - 56
American Oil and Gas Reporter - April 2018 - 57
American Oil and Gas Reporter - April 2018 - 58
American Oil and Gas Reporter - April 2018 - 59
American Oil and Gas Reporter - April 2018 - 60
American Oil and Gas Reporter - April 2018 - 61
American Oil and Gas Reporter - April 2018 - 62
American Oil and Gas Reporter - April 2018 - 63
American Oil and Gas Reporter - April 2018 - 64
American Oil and Gas Reporter - April 2018 - 65
American Oil and Gas Reporter - April 2018 - 66
American Oil and Gas Reporter - April 2018 - 67
American Oil and Gas Reporter - April 2018 - 68
American Oil and Gas Reporter - April 2018 - 69
American Oil and Gas Reporter - April 2018 - 70
American Oil and Gas Reporter - April 2018 - 71
American Oil and Gas Reporter - April 2018 - 72
American Oil and Gas Reporter - April 2018 - 73
American Oil and Gas Reporter - April 2018 - 74
American Oil and Gas Reporter - April 2018 - 75
American Oil and Gas Reporter - April 2018 - 76
American Oil and Gas Reporter - April 2018 - 77
American Oil and Gas Reporter - April 2018 - 78
American Oil and Gas Reporter - April 2018 - 79
American Oil and Gas Reporter - April 2018 - 80
American Oil and Gas Reporter - April 2018 - 81
American Oil and Gas Reporter - April 2018 - 82
American Oil and Gas Reporter - April 2018 - 83
American Oil and Gas Reporter - April 2018 - 84
American Oil and Gas Reporter - April 2018 - 85
American Oil and Gas Reporter - April 2018 - 86
American Oil and Gas Reporter - April 2018 - 87
American Oil and Gas Reporter - April 2018 - 88
American Oil and Gas Reporter - April 2018 - 89
American Oil and Gas Reporter - April 2018 - 90
American Oil and Gas Reporter - April 2018 - 91
American Oil and Gas Reporter - April 2018 - 92
American Oil and Gas Reporter - April 2018 - 93
American Oil and Gas Reporter - April 2018 - 94
American Oil and Gas Reporter - April 2018 - 95
American Oil and Gas Reporter - April 2018 - 96
American Oil and Gas Reporter - April 2018 - 97
American Oil and Gas Reporter - April 2018 - 98
American Oil and Gas Reporter - April 2018 - 99
American Oil and Gas Reporter - April 2018 - 100
American Oil and Gas Reporter - April 2018 - 101
American Oil and Gas Reporter - April 2018 - 102
American Oil and Gas Reporter - April 2018 - 103
American Oil and Gas Reporter - April 2018 - 104
American Oil and Gas Reporter - April 2018 - 105
American Oil and Gas Reporter - April 2018 - 106
American Oil and Gas Reporter - April 2018 - 107
American Oil and Gas Reporter - April 2018 - 108
American Oil and Gas Reporter - April 2018 - 109
American Oil and Gas Reporter - April 2018 - 110
American Oil and Gas Reporter - April 2018 - 111
American Oil and Gas Reporter - April 2018 - 112
American Oil and Gas Reporter - April 2018 - 113
American Oil and Gas Reporter - April 2018 - 114
American Oil and Gas Reporter - April 2018 - 115
American Oil and Gas Reporter - April 2018 - 116
American Oil and Gas Reporter - April 2018 - 117
American Oil and Gas Reporter - April 2018 - 118
American Oil and Gas Reporter - April 2018 - 119
American Oil and Gas Reporter - April 2018 - 120
American Oil and Gas Reporter - April 2018 - 121
American Oil and Gas Reporter - April 2018 - 122
American Oil and Gas Reporter - April 2018 - 123
American Oil and Gas Reporter - April 2018 - 124
American Oil and Gas Reporter - April 2018 - 125
American Oil and Gas Reporter - April 2018 - 126
American Oil and Gas Reporter - April 2018 - 127
American Oil and Gas Reporter - April 2018 - 128
American Oil and Gas Reporter - April 2018 - 129
American Oil and Gas Reporter - April 2018 - 130
American Oil and Gas Reporter - April 2018 - 131
American Oil and Gas Reporter - April 2018 - 132
American Oil and Gas Reporter - April 2018 - 133
American Oil and Gas Reporter - April 2018 - 134
American Oil and Gas Reporter - April 2018 - 135
American Oil and Gas Reporter - April 2018 - 136
American Oil and Gas Reporter - April 2018 - 137
American Oil and Gas Reporter - April 2018 - 138
American Oil and Gas Reporter - April 2018 - 139
American Oil and Gas Reporter - April 2018 - 140
American Oil and Gas Reporter - April 2018 - 141
American Oil and Gas Reporter - April 2018 - 142
American Oil and Gas Reporter - April 2018 - 143
American Oil and Gas Reporter - April 2018 - 144
American Oil and Gas Reporter - April 2018 - 145
American Oil and Gas Reporter - April 2018 - 146
American Oil and Gas Reporter - April 2018 - 147
American Oil and Gas Reporter - April 2018 - 148
American Oil and Gas Reporter - April 2018 - 149
American Oil and Gas Reporter - April 2018 - 150
American Oil and Gas Reporter - April 2018 - 151
American Oil and Gas Reporter - April 2018 - 152
American Oil and Gas Reporter - April 2018 - 153
American Oil and Gas Reporter - April 2018 - 154
American Oil and Gas Reporter - April 2018 - 155
American Oil and Gas Reporter - April 2018 - 156
American Oil and Gas Reporter - April 2018 - 157
American Oil and Gas Reporter - April 2018 - 158
American Oil and Gas Reporter - April 2018 - 159
American Oil and Gas Reporter - April 2018 - 160
American Oil and Gas Reporter - April 2018 - 161
American Oil and Gas Reporter - April 2018 - 162
American Oil and Gas Reporter - April 2018 - 163
American Oil and Gas Reporter - April 2018 - 164
American Oil and Gas Reporter - April 2018 - 165
American Oil and Gas Reporter - April 2018 - 166
American Oil and Gas Reporter - April 2018 - 167
American Oil and Gas Reporter - April 2018 - 168
American Oil and Gas Reporter - April 2018 - 169
American Oil and Gas Reporter - April 2018 - 170
American Oil and Gas Reporter - April 2018 - 171
American Oil and Gas Reporter - April 2018 - 172
American Oil and Gas Reporter - April 2018 - 173
American Oil and Gas Reporter - April 2018 - 174
American Oil and Gas Reporter - April 2018 - 175
American Oil and Gas Reporter - April 2018 - 176
American Oil and Gas Reporter - April 2018 - 177
American Oil and Gas Reporter - April 2018 - 178
American Oil and Gas Reporter - April 2018 - 179
American Oil and Gas Reporter - April 2018 - 180
http://www.nxtbook.com/nxtbooks/aogr/201911
http://www.nxtbook.com/nxtbooks/aogr/201910
http://www.nxtbook.com/nxtbooks/aogr/201909
http://www.nxtbook.com/nxtbooks/aogr/201908
http://www.nxtbook.com/nxtbooks/aogr/201907
http://www.nxtbook.com/nxtbooks/aogr/201906
http://www.nxtbook.com/nxtbooks/aogr/201905
http://www.nxtbook.com/nxtbooks/aogr/201904
http://www.nxtbook.com/nxtbooks/aogr/201903
http://www.nxtbook.com/nxtbooks/aogr/201902
http://www.nxtbook.com/nxtbooks/aogr/201901
http://www.nxtbook.com/nxtbooks/aogr/201812
http://www.nxtbook.com/nxtbooks/aogr/201811
http://www.nxtbook.com/nxtbooks/aogr/201810
http://www.nxtbook.com/nxtbooks/aogr/pbios_201810
http://www.nxtbook.com/nxtbooks/aogr/201809
http://www.nxtbook.com/nxtbooks/aogr/201808
http://www.nxtbook.com/nxtbooks/aogr/201807
http://www.nxtbook.com/nxtbooks/aogr/201806
http://www.nxtbook.com/nxtbooks/aogr/201805
http://www.nxtbook.com/nxtbooks/aogr/201804
http://www.nxtbook.com/nxtbooks/aogr/201803
http://www.nxtbook.com/nxtbooks/aogr/201802
http://www.nxtbook.com/nxtbooks/aogr/201801
http://www.nxtbook.com/nxtbooks/aogr/201712
http://www.nxtbook.com/nxtbooks/aogr/201711
http://www.nxtbook.com/nxtbooks/aogr/201710
http://www.nxtbook.com/nxtbooks/aogr/201709
http://www.nxtbook.com/nxtbooks/aogr/201708
http://www.nxtbook.com/nxtbooks/aogr/201707
http://www.nxtbook.com/nxtbooks/aogr/201706
http://www.nxtbook.com/nxtbooks/aogr/201705
http://www.nxtbook.com/nxtbooks/aogr/201704
http://www.nxtbook.com/nxtbooks/aogr/201703
http://www.nxtbook.com/nxtbooks/aogr/201702
http://www.nxtbook.com/nxtbooks/aogr/201701
http://www.nxtbook.com/nxtbooks/aogr/201612
http://www.nxtbook.com/nxtbooks/aogr/201611
http://www.nxtbook.com/nxtbooks/aogr/201610
http://www.nxtbook.com/nxtbooks/aogr/pbios2016_programguide
http://www.nxtbook.com/nxtbooks/aogr/201609
http://www.nxtbook.com/nxtbooks/aogr/201608
http://www.nxtbook.com/nxtbooks/aogr/201607
http://www.nxtbook.com/nxtbooks/aogr/201606
http://www.nxtbook.com/nxtbooks/aogr/201605
http://www.nxtbook.com/nxtbooks/aogr/201604
http://www.nxtbook.com/nxtbooks/aogr/201603
http://www.nxtbook.com/nxtbooks/aogr/201602
http://www.nxtbook.com/nxtbooks/aogr/201601
http://www.nxtbook.com/nxtbooks/aogr/201512
http://www.nxtbook.com/nxtbooks/aogr/201511
http://www.nxtbook.com/nxtbooks/aogr/201510
http://www.nxtbook.com/nxtbooks/aogr/201509
http://www.nxtbook.com/nxtbooks/aogr/201508
http://www.nxtbook.com/nxtbooks/aogr/201507
http://www.nxtbook.com/nxtbooks/aogr/201506
http://www.nxtbook.com/nxtbooks/aogr/201505
http://www.nxtbook.com/nxtbooks/aogr/201504
http://www.nxtbook.com/nxtbooks/aogr/201503
http://www.nxtbook.com/nxtbooks/aogr/201502
http://www.nxtbook.com/nxtbooks/aogr/201501
http://www.nxtbook.com/nxtbooks/aogr/201412
http://www.nxtbook.com/nxtbooks/aogr/201411
http://www.nxtbook.com/nxtbooks/aogr/201410
http://www.nxtbook.com/nxtbooks/aogr/201409
http://www.nxtbook.com/nxtbooks/aogr/pbios2014_programguide
http://www.nxtbook.com/nxtbooks/aogr/201408
http://www.nxtbook.com/nxtbooks/aogr/201407
http://www.nxtbook.com/nxtbooks/aogr/201406
http://www.nxtbook.com/nxtbooks/aogr/201405
http://www.nxtbook.com/nxtbooks/aogr/201404
http://www.nxtbook.com/nxtbooks/aogr/201403
http://www.nxtbook.com/nxtbooks/aogr/201402
http://www.nxtbook.com/nxtbooks/aogr/201401
http://www.nxtbook.com/nxtbooks/aogr/201312
http://www.nxtbook.com/nxtbooks/aogr/201311
http://www.nxtbook.com/nxtbooks/aogr/201310
http://www.nxtbook.com/nxtbooks/aogr/201309
http://www.nxtbook.com/nxtbooks/aogr/201308
http://www.nxtbook.com/nxtbooks/aogr/201307
http://www.nxtbook.com/nxtbooks/aogr/201306
http://www.nxtbook.com/nxtbooks/aogr/201305
http://www.nxtbook.com/nxtbooks/aogr/201304
http://www.nxtbook.com/nxtbooks/aogr/201303
http://www.nxtbook.com/nxtbooks/aogr/201302
http://www.nxtbook.com/nxtbooks/aogr/201301
http://www.nxtbook.com/nxtbooks/aogr/201212
http://www.nxtbook.com/nxtbooks/aogr/201211
http://www.nxtbook.com/nxtbooks/aogr/201210
http://www.nxtbook.com/nxtbooks/aogr/201209
http://www.nxtbook.com/nxtbooks/aogr/2012_pbios
http://www.nxtbook.com/nxtbooks/aogr/201208
http://www.nxtbook.com/nxtbooks/aogr/201207
http://www.nxtbook.com/nxtbooks/aogr/201206
http://www.nxtbook.com/nxtbooks/aogr/201205
http://www.nxtbook.com/nxtbooks/aogr/201204
http://www.nxtbook.com/nxtbooks/aogr/201203
http://www.nxtbook.com/nxtbooks/aogr/201202
http://www.nxtbook.com/nxtbooks/aogr/201201
http://www.nxtbook.com/nxtbooks/demo/aogr_clone
http://www.nxtbook.com/nxtbooks/aogr/201112
http://www.nxtbookMEDIA.com