American Oil and Gas Reporter - September 2020 - 31

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sider methane emissions. Consequently,
the agency concludes, "The (2020) amendments rescind emission limits for methane,
but keep limits for VOCs."
Sources in the production and processing segments include well completions,
pneumatic pumps, pneumatic controllers,
gathering and boosting compressors, natural gas processing plants, fugitive emissions and storage tanks, EPA says.
It adds, "Because the controls to reduce
VOC emissions also reduce methane,
separate methane limitations for these
segments are redundant."
And, because it has rescinded methane
limits for the production and processing
segments, EPA says it no longer is required
to issue emission guidelines to address
existing sources in those segments under
CAA Section 111(d).
Technical Issue Regulations
According to a summary distributed
by the Kansas Independent Oil & Gas
Association, the second part of EPA's
final rule-the technical amendments to
the 2016 NSPS-addresses a range of
technical and implementation issues.
These include fugitive emission requirements, record keeping and reporting requirements, provisions to apply to use an
alternative means of emission limitations,
pneumatic pump standards, storage vessel
standard applicability determinations, and
engineer certifications.
For monitoring fugitive emissions,
KIOGA says, the rule reduces the frequency of required monitoring for gath-

ering and boosting compressor stations
from quarterly to semiannually, and keeps
it at semi-annually for non-low-production
wells. Wells producing less than 15 barrels
of oil or 90 Mcf of gas a day are exempt
from monitoring requirements.
In addition, KIOGA says, the final
rule:
· Allows an owner/operator to determine the best means to ensure that all
components are monitored, rather than
having to include a site map and an observation path in his monitoring plan;
· Streamlines record keeping and reporting requirements;
· Revises the schedule for making
fugitive emission repairs; and
· Clarifies actions that constitute a
modification for a well site that is a separate tank battery surface site.
As to alternative means of emissions
limitations (AMEL), KIOGA says the
final rule incorporates state standards for
well sites and compressor stations in California, Colorado, Ohio, Pennsylvania
and Texas; for well sites in Utah; and an
alternative for gathering and boosting
compressor stations in Texas.
The final rule also streamlines the
process for requesting new alternative
emissions standards as state, local and
tribal programs continue to develop, KIOGA mentions.
In addition, it says, the rule amends
the application requirements for requests
to use an AMEL, and gives EPA discretion,
in certain circumstances, for broad approval of alternatives.

Nevertheless, worries IPAA's Fuller,
"The AMEL permitting process currently
is unsuited to the oil and gas production
industry. EPA is trying to allow more
flexibility in these regulatory revisions,
but the underlying CAA provisions may
inhibit success."
Regarding pneumatic pumps, KIOGA
says the final rule:
· Expands an existing exemption to
cover pumps at green-field sites; and
· Expands the types of monitoring
that owners/operators may use to demonstrate that closed-vent systems are operating with no detectable emissions.
For engineer certifications of closedvent systems, KIOGA says the final rule
allows either a professional engineer or
in-house engineer with appropriate knowledge to certify the system is designed
and operated as required.
And for storage vessels, KIOGA continues, the final rule:
· Clarifies how to calculate potential
VOC emissions for individual storage
tanks to determine whether standards in
the rule apply; and
· Establishes separate criteria for calculating potential VOC emissions from
individual storage vessels that are part of
a controlled tank battery.
Prepublication versions of the two
final rules and other related information,
EPA
says,
are
available
at
https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/actions-and-notices-about-oil-and-naturalgas#regactions.
❒

NY Deems Drilling Waste Hazardous
ALBANY, N.Y.-New York Governor
Andrew Cuomo on Aug. 3 signed
S3392/A2655, legislation that classifies
oil and natural gas waste as hazardous,
which places it under a stricter regulatory
regime.
According to Independent Oil & Gas
Association of New York President Tim
Hull, the impetus for the legislation
came from lawmakers' desire to discourage out-of-state producers from
sending cuttings and other Marcellus
Shale waste to a few county landfills
in New York. Senator Rachel May, DSyracuse, sponsored the bill in the Senate, while Assemblyman Steve Englebright, D-East Setauket, authored the
Assembly version.
"Legislators wanted to put a stop to
that," relates Hull, vice president of Empire
Energy in Erie County, N.Y. "Everybody
expects this sort of thing from New York

these days. The fact this passed is unpleasant, but also unsurprising."
He notes that resisting anti-industry
initiatives has become increasingly difficult in recent sessions, and IOGA NY
did not take a position on S3392/A2655.
"Legislators have been trying to make it
illegal to put out-of-state drill cuttings
into landfills for a while," he observes.
"Every year, New York legislators have
a handful of bills that affect the oil and
gas industry, and this was one that passed
in 2020. With Democrats holding majorities in both the Senate and Assembly,
it is harder to slow such bills."
Press releases from Cuomo's office
describe the new law as a means to accelerate the state's transition away from
fossil fuels to a carbon-neutral, "green"
economy. May and Englebright claim the
legislation closes a "dangerous loophole."
As for how IOGA NY expects the

new hazardous waste requirements will
impact members, Hull acknowledges
that it will increase drilling costs in
New York, but says it is difficult to
know how much at a time of little or
no New York drilling. Not only has the
state precluded unconventional activity
by codifying a high-volume hydraulic
fracturing ban this year (AOGR, May
2020, pg. 33), he notes, but market
conditions largely have companies postponing conventional projects.
"Wastewaters and such already are
taken to disposal facilities," he says. "For
cuttings, it is going to raise costs and
make disposal more difficult. That is not
much of an issue right now, but it could
become one as activity recovers."
New York's oil and gas industry may
be besieged, Hull says, but it is not giving
up. "We are still here, doing what we can
to survive," he assures.
❒
SEPTEMBER 2020 31


https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/actions-and-notices-about-oil-and-natural-gas#regactions https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/actions-and-notices-about-oil-and-natural-gas#regactions https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/actions-and-notices-about-oil-and-natural-gas#regactions https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/actions-and-notices-about-oil-and-natural-gas#regactions

American Oil and Gas Reporter - September 2020

Table of Contents for the Digital Edition of American Oil and Gas Reporter - September 2020

Contents
American Oil and Gas Reporter - September 2020 - Intro
American Oil and Gas Reporter - September 2020 - 1
American Oil and Gas Reporter - September 2020 - 2
American Oil and Gas Reporter - September 2020 - 3
American Oil and Gas Reporter - September 2020 - 4
American Oil and Gas Reporter - September 2020 - Contents
American Oil and Gas Reporter - September 2020 - 6
American Oil and Gas Reporter - September 2020 - 7
American Oil and Gas Reporter - September 2020 - 8
American Oil and Gas Reporter - September 2020 - 9
American Oil and Gas Reporter - September 2020 - 10
American Oil and Gas Reporter - September 2020 - 11
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