November 1, 2021, EPA proposed revisions to current control requirements (New Source Performance Standard OOOO) and addition of new requirements for methane emissions from:
- Oil and Natural Gas Well Sites
- Natural Gas Gathering and Boosting Compressor Stations
- Natural Gas Processing
- Transmission and Storage
This would be the third increase in emission requirements for these sectors of industry since 2002. EPA is asking for public comments on the proposal which they say will form the basis of a “supplemental proposal” slated for 2022 and eventual promulgation in “late 2022”. In other words, EPA is making the announcement while COP26 is going on in Glasgow, Scotland not because the proposal is ready.
The proposal would require “hundreds of thousands” of oil and natural gas well sites throughout the country to install measurement systems to measure “fugitive emissions” of methane (methane that leaks out of pipelines and equipment at those sites). Once identified those “fugitive emissions” would need to be controlled by tightening junctions or replacing parts so that the emissions are minimized or eliminated. These kind of controls of fugitive emissions have been in place at refineries and chemical plants for decades, but not at well sites and gas collection and processing facilities in the ways now proposed.
Well sites with more than 3 tons per year of “estimated” fugitive emissions will need to survey the potential fugitive emission points quarterly using traditional methods which use a handheld device to find leaking locations or using Optical Gas Imaging (OGI) systems to discover the leaks. The methodology and use of OGI is one of the reasons for delaying the proposal to hash out how OGI would be used.
Once a leak is discovered, it must be repaired within certain time limits.
All new and existing wells, compressor stations, flares, tanks and hatches would be included in surveys.
Because the old methods of “sniffing” each potential leak location (EPA Method 21) is labor intensive and difficult to manage, EPA is requesting that new wide area survey techniques such as OGI be evaluated and proposed by owners and equipment manufacturers for consideration by EPA to accomplish this currently expensive task. The proposal schedule is a short time period for much of a research effort.
The proposal also requires zero emissions from pneumatic controllers, elimination of venting of gas from oil well locations, greatly increased controls on all oil and gas storage tanks, unloading of liquids, and more controls on compressors. EPA is also considering controls on abandoned and unplugged wells, oil field flares, pipeline pigging, and tank truck loading.
The proposal seeks to reduce 41 million tons of methane emissions through 2035 and cost $49 billion over that time span.
Contract TRC for assistance at any facility with all or parts of the program implementation and analysis of costs for your facilities.
Sharing Our Perspectives
Our practitioners share their insights and perspectives on the trends and challenges shaping the market.
EPA Signs New Rule Affecting Air Emissions from Stationary Combustion Turbines
September 16, 2024
EPA finalized the residual risk and technology review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Combustion Turbines.
EPA Proposes New Guidance on Air Quality Analysis for Permits
January 5, 2024
On October 23, 2023, the US EPA proposed changes to the Guideline on Air Quality Models and the US EPA model AERMOD
Modeling of Fogging and Icing Events
December 14, 2023
In recent years, various agencies across the country have become committed to understanding the impacts of fog generated by cooling systems. At first glance, fog created by cooling towers may not appear to be a significant problem, however, it can have adverse effects on the public. Fog can impair visibility for people driving on roads and if temperatures are below freezing, fog can cause the formation of rime ice on surfaces. To understand the consequences of fog created by these cooling systems, experts have devised advanced modeling techniques.
EPA Issues Information Collection Request for Plywood and Composite Wood Products Source Operators
March 17, 2022
EPA issued an Information Collection Request (ICR) to develop new emission standards for inclusion in the Plywood and Composite Wood Products (PCWP) National Emissions Standards for Hazardous Air Pollutants (NESHAP).
EPA Lifts Stay of Standards for New Lean Premix and Diffusion Flame Gas-fired Combustion Turbines
March 14, 2022
The EPA Administration signed a notice to finalize amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Combustion Turbines
TRC Acquires United Sciences Testing, Inc., Expanding Air Management Capabilities
February 23, 2022
TRC Companies (“TRC”), announced the expansion of its Air Management capabilities with the acquisition of United Sciences Testing, Inc. (USTI), who provides emissions testing services to utility and industrial clients within the Great Lakes and Midwest regions of the US.
Air Emissions Permitting: What Analytical Laboratories Need to Know About Compliance
December 18, 2021
The independent testing of liquid and solid samples is a critical way that businesses demonstrate regulatory compliance. The laboratories that perform these analyses are also subject to environmental rules and should closely track their operations to ensure they are meeting compliance obligations.
EPA Proposes Changes to Methane Control at Petroleum Operations
November 10, 2021
New Source Performance Standard for Methane Control at Petroleum Operations in 2022
PFAS Air Emissions Standards and Trends for Summer 2021
August 17, 2021
Environmental impacts of PFAS in ambient air leads to states implementing PFAS air-related thresholds.
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
July 22, 2021
It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.
EPA Proposes New Emissions Limits for Combustion Turbines
May 22, 2021
After 15 years of legal limbo, combustion turbines could be facing new emissions standards under a proposal introduced by the EPA.
EPA Ramps Up Inspections and Enforcement Actions
May 14, 2021
EPA’s acting enforcement chief, Larry Starfield, directs agents to ramp up inspections in communities known to be afflicted by pollution
South Coast Air Quality Management District Rule 2305: Warehouse Indirect Source Rule
April 7, 2021
The rule is intended to reduce local and regional emissions of NOx and diesel particulate matter (PM).
EPA Finalizes Reversal of “Once In Always In” Air Pollution Policy
November 18, 2020
On October 1, 2020, the EPA finalized a ruling that no longer enforces the “once in, always in” air emissions policy.
TRC Awarded a Yahara WINS Grant
August 28, 2020
TRC was recently awarded a Yahara WINS grant to develop a pilot scale simple aeration method for removing phosphorous from the discharge of manure digesters. The grant application was developed and submitted by: Bob Stanforth, Alyssa Sellwood, Mike Ursin, Ted O’Connell, Ken Quinn, and John Rice, who are members of multiple TRC CORE teams.
New York State Finalizes Emission Limits for Power Generators
January 21, 2020
On January 16, 2020, the New York State Department of Environmental Conservation (NYSDEC) finalized a rulemaking limiting nitrogen oxide (NOx) emissions from existing simple cycle and regenerative peaking combustion turbines with a nameplate capacity of 15 megawatts (MW) or greater during the ozone season (May 1 – October 31).
New York State Proposes Emissions Limits for Power Generators
March 22, 2019
On February 27, 2019, the New York State Department of Environmental Conservation (NYSDEC) released a proposed rulemaking limiting nitrogen oxide (NOx) emissions from existing simple cycle and regenerative peaking combustion turbines with a nameplate capacity of 15 megawatts (MW) or greater during the ozone season (May 1 – October 31).
PM2.5 Annual NAAQS Revised
May 7, 2024
The U.S. EPA issued a final rule based on its reconsideration of its 2020 decision to retain the primary and secondary National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) without revision.
EPA Issues Regulations for Oil and Natural Gas Sector Tank Emissions
April 30, 2024
Storage Vessel or Tank Battery Operators Must Reduce Emissions by 95%.
EPA Proposes Rules for IRA-mandated Waste Emissions Charge for Methane
February 6, 2024
EPA proposed rules to implement the Waste Emissions Charge (WEC) program for facilities that exceed a waste emissions threshold
EPA Proposes New Guidance on Air Quality Analysis for Permits
January 5, 2024
On October 23, 2023, the US EPA proposed changes to the Guideline on Air Quality Models and the US EPA model AERMOD
Modeling of Fogging and Icing Events
December 14, 2023
In recent years, various agencies across the country have become committed to understanding the impacts of fog generated by cooling systems. At first glance, fog created by cooling towers may not appear to be a significant problem, however, it can have adverse effects on the public. Fog can impair visibility for people driving on roads and if temperatures are below freezing, fog can cause the formation of rime ice on surfaces. To understand the consequences of fog created by these cooling systems, experts have devised advanced modeling techniques.
EPA Proposes Regulation of Green House Gas Emissions
July 10, 2023
This article highlights the EPA’s proposed rules to regulate greenhouse gas emissions from power plants and the potential impact on new and existing fossil fuel-fired facilities.
TRC Acquires United Sciences Testing, Inc., Expanding Air Management Capabilities
February 23, 2022
TRC Companies (“TRC”), announced the expansion of its Air Management capabilities with the acquisition of United Sciences Testing, Inc. (USTI), who provides emissions testing services to utility and industrial clients within the Great Lakes and Midwest regions of the US.
EPA Adds First New Hazardous Air Pollutant Since 1990
January 14, 2022
EPA finalized a rule to add 1-bromopropane to the federal list of hazardous air pollutants (HAPs) on December 22, 2022.
Air Emissions Permitting: What Analytical Laboratories Need to Know About Compliance
December 18, 2021
The independent testing of liquid and solid samples is a critical way that businesses demonstrate regulatory compliance. The laboratories that perform these analyses are also subject to environmental rules and should closely track their operations to ensure they are meeting compliance obligations.
EPA Proposes Changes to Methane Control at Petroleum Operations
November 10, 2021
New Source Performance Standard for Methane Control at Petroleum Operations in 2022
PFAS Air Emissions Standards and Trends for Summer 2021
August 17, 2021
Environmental impacts of PFAS in ambient air leads to states implementing PFAS air-related thresholds.
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
July 22, 2021
It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.
EPA Ramps Up Inspections and Enforcement Actions
May 14, 2021
EPA’s acting enforcement chief, Larry Starfield, directs agents to ramp up inspections in communities known to be afflicted by pollution
South Coast Air Quality Management District Rule 2305: Warehouse Indirect Source Rule
April 7, 2021
The rule is intended to reduce local and regional emissions of NOx and diesel particulate matter (PM).
EPA Clean Air Act Rulemaking Announced December 2020
December 31, 2020
EPA announces Clean Air Act Rulemaking in the final month of the current administration and indicates more could be announced before the new administration comes into office.
New Jersey’s Landmark Environmental Justice Law
November 24, 2020
Many facilities require air quality measurement testing programs to verify compliance with regulatory permits, assess new air pollution control equipment performance and certify the continuous emission monitoring (CEM) equipment associated with the production processes. Proper, accurate, efficient and timely execution of compliance test programs reduces costs while providing defensible data that are representative of source emissions. In the absence of proper planning, important details can be overlooked, resulting in last minute changes that are costly with the potential to delay the test program. Proper planning, coupled with informed oversight, ensures the test program is performed successfully, in full accordance with appropriate methods and agency coordination and supported by the full complement of required measurement and process data. This webinar, tailored to meet the needs of facilities in Illinois, Indiana, Iowa, Michigan, Missouri and Wisconsin, shares best practices and outlines key considerations to equip participants with the skills to manage air quality measurement programs that achieve technically-sound results and fully support the compliance and operational objectives of all types of facilities. Topics discussed by TRC’s Dan Grabowski and Doug Ryan include: A systematic approach to stack test planning and oversight General notification and reporting requirements EPA’s Electronic Reporting Tool (ERT) Update on EPA’s Stationary Source Audit Program (SSAP)
EPA Finalizes Reversal of “Once In Always In” Air Pollution Policy
November 18, 2020
On October 1, 2020, the EPA finalized a ruling that no longer enforces the “once in, always in” air emissions policy.
TRC Awarded a Yahara WINS Grant
August 28, 2020
TRC was recently awarded a Yahara WINS grant to develop a pilot scale simple aeration method for removing phosphorous from the discharge of manure digesters. The grant application was developed and submitted by: Bob Stanforth, Alyssa Sellwood, Mike Ursin, Ted O’Connell, Ken Quinn, and John Rice, who are members of multiple TRC CORE teams.
New York State Finalizes Emission Limits for Power Generators
January 21, 2020
On January 16, 2020, the New York State Department of Environmental Conservation (NYSDEC) finalized a rulemaking limiting nitrogen oxide (NOx) emissions from existing simple cycle and regenerative peaking combustion turbines with a nameplate capacity of 15 megawatts (MW) or greater during the ozone season (May 1 – October 31).
EPA Proposes Rules for IRA-mandated Waste Emissions Charge for Methane
February 6, 2024
EPA proposed rules to implement the Waste Emissions Charge (WEC) program for facilities that exceed a waste emissions threshold
PHMSA Gas Transmission RIN2 Rule Now Effective
July 24, 2023
TRC summarizes the revised or added sections of RIN2.
PHMSA Releases Proposed Rulemaking for Pipeline Safety and Gas Pipeline Leak Detection and Repair
June 15, 2023
TRC explains the Proposed Rulemaking for Pipeline Safety and Gas Pipeline Leak Detection and Repair
PHMSA Issues Gas Gathering Final Rule Summary & Requirements
November 30, 2021
PHMSA announced that they issued a final rule that significantly expands Federal pipeline safety oversight to all onshore gas gathering pipelines.
EPA Proposes Changes to Methane Control at Petroleum Operations
November 10, 2021
New Source Performance Standard for Methane Control at Petroleum Operations in 2022
Environmental Compliance Key for Transloading Success
February 24, 2021
Transloading projects that support the transfer of oil from truck to rail and vice versa are an increasing growth opportunity for the rail industry. However, since transfer requires the handling of the goods, transloading can be expensive, and the risk of damage and spills is high.
TCEQ to Assume Oil and Gas Wastewater Permitting from RRC
January 11, 2021
Historically, the Railroad Commission of Texas has been responsible for wastewater permitting of upstream oil and gas facilities under a Memorandum of Understanding with the Texas Commission on Environmental Quality.
INGAA Foundation Interview with Lauren O’Donnell
June 22, 2020
TRC’s own Lauren O’Donnell is currently the elected Chair of the INGAA Foundation. The Foundation’s primary activity is to sponsor research aimed at promoting natural gas use and safe, efficient pipeline construction and operation.
Targeting Perfection in the Construction and Operation of Pipelines
October 18, 2019
To have an impact on the delivery or operation of a pipeline, it’s vital to eliminate the intra- and inter-company barriers, including those in the areas of communications, culture and technology.
PHMSA Publishes New Rules to Increase the Safety of Hazardous Liquid Pipelines and Gas Transmission Pipelines
September 25, 2019
The Pipeline and Hazardous Materials Safety Administration this week published important new rules aimed at improving pipeline safety.
TRC Chosen to Provide Array of Integrated Services on Midship Pipeline Project
August 28, 2018
TRC has been awarded contracts for environmental consulting, engineering and field services and another for stem-to-stern Engineer, Procure and Construct (EPC) contract for three compressor stations.
