American Oil and Gas Reporter - April 2015 - 181

Endangered Species
Pennsylvania operators can expect to
see increased attention to threatened and
endangered species, warned Scott Roberts,
a consultant to PIOGA on regulatory issues. Many states are seeing significant
increases in Endangered Species Act protections and the associated impacts on
field activities, but he pointed out the
issue was less crucial for those working
in the commonwealth.
One Pennsylvania native, the northern
long-eared bat, will be of concern, Roberts
stated. He discussed how researchers discovered in 2005 that a number of bats hibernating in a cave outside Albany, N.Y.,
had a fatal virus, white-nose syndrome.
"That particular virus rapidly spread
throughout the hibernaculum in Pennsylvania . . . almost exclusively by biologists, researchers and resource agency
personnel who went into these caves to
check for white nose syndrome. They
did not take the necessary precautions to
make sure they were not carrying the
spores. The result is this relatively common
bat species has been 95-99 percent wiped
out in the state."
In response, the government began
acting on petitions submitted to the U.S.
Fish & Wildlife Service that sought ESA
protection for the northern long-eared
bat. Comments by PIOGA and the Independent Petroleum Association of America
called that action inappropriate, Roberts
said, and they were joined by a consortium
of Northeast wildlife agencies, including
Pennsylvania's game and fish commissions, that urged the agency to try something different.
While USFWS considers how to proceed, the agency has published proposed
regulations under Section 4(d) of the
ESA about how it will manage a listing.
The proposal contains several exemptions, including forest management activities, Roberts reported, adding that
USFWS exempted them because they
typically affected less than 2.0 percent
of forest lands.

"PIOGA is trying to put together comments based on the fact that, if you look
at five years of data collected at Pennsylvania's Department of Conservation
and Natural Resources, oil and gas activities only affect about 0.10 percent of the
forest, and therefore this activity should
be exempt in the same way as forest
management would be," Roberts said.

Air Quality
Kicking off a presentation about air
quality challenges, Ron Cusano, Air Quality Issues Subcommittee chairman for
PIOGA'S Environmental Committee and
an attorney with Schnader Harrison Segal
& Lewis LLP, said amendments to Subpart
OOOO, the federal new source performance standard applicable to oil and gas,
were now in force. The EPA changed requirements applicable to well completions,
storage vessels, rod and packing emissions
from reciprocating compressors, the definition of responsible officials, and changes
to civil penalties of the affirmative administrative defense, he said.
When EPA amended air quality regulations in 2012, Cusano reported it changed
its low-pressure gas well definition. The
new rule exempts some wells according
to the relationship between their depth,
reservoir pressure and flowline pressure.
PIOGA and IPAA then filed petitions
for administrative reconsideration of the
definition, but EPA reissued the 2012
definition, Cusano said. He said EPA admitted it received the comments before
the deadline, but lost them.
"Therefore, the agency did not respond
to PIOGA's comments," Cusano said.
"More importantly, the changes EPA
made to well completions might provide
the kind of relief PIOGA sought, particularly for the conventional operators with
very reduced flowback periods."
The Nov. 25 revisions to 40 CFR Part
98 Subpart W, the greenhouse gas emission
regulations for petroleum and natural gas
systems, took effect Jan. 1, and will affect
the reports due March 31, 2016, said

Participating in a presentation on air quality challenges at the Pennsylvania Independent Oil & Gas
Association meeting are,
from left, Roy Rakiewicz
with All4 Inc., Ron Cusano
with Schnader Harrison
Segal & Lewis LLC, and
Meghan Barber with All4.
The meeting was held
Feb. 24-25 at the Seven
Springs Mountain Resort
in Champion, Pa.

Threatened and endangered species remain a regulatory concern, warns Scott
Roberts, a consultant to the Pennsylvania
Independent Oil & Gas Association. He
told the association's winter meeting
federal efforts to reverse a fatal syndrome
affecting the northern long-eared bat
could impact oil and gas operations.

Meghan Barber, a project engineer with
All4 Inc. The latest revision will reduce
some reporting burdens for producers while
increasing other requirements, she assessed.
EPA is allowing optical imaging to
detect emissions from reciprocating engines
and centrifugal compressors, and added
guidance on missing data procedures. On
the negative side, Barber said, several of
the agency's calculation and reporting
methods require producers to differentiate
between types of completion or workover,
and ask for sub-basin information.

Condensate Safety
As Pennsylvania and West Virginia
operators develop wet gas plays, condensate safety becomes even more important, said Wayne Vanderhoof, president
of RJR Safety Inc.
The principal risks of condensate are
its volatility, a weight that allows it to
float on water while being heavier than
air, nonsolubility in water, and the ease
with which it evaporates, he detailed.
Vanderhoof pointed out how condensate in water tanks on a well site posed a
multiple threat. He said because it floated
on top of water and evaporated readily,
workers could open a thief hatch and be
engulfed by vapors.
Because of its flammability, he warned
even a small spark-caused by static electricity or using a cell phone as a flashlight
to check a tank-could ignite fumes. If
condensate vapor leaks from a tank, it
sinks and spreads, meaning that idling
trucks parked nearby could serve as an
ignition source, he pointed out.
"There is no way to eliminate condensate's hazards, so you have to try to
control it and protect the worker," he asserted.
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