The Council is formulating comments on two important upcoming rules that could have significant impacts on our sector – the OSHA Vaccine Mandate and EPA’s Methane Rule. In order to ensure that the opinions and technical expertise of all Member Companies is represented in these comments, the Council plans to form task forces to assist. Contact Tim Tarpley should you wish to participate in either task force.
EPA Methane Rule
The new EPA methane rule has several provisions of note, including:
- Well sites with estimated emissions of three tons per year or more must monitor for leaks using optical gas imaging (OGI) or Method 21 quarterly and promptly repair any leaks found. EPA estimates sites emitting three tons or more per year are responsible for approximately 86% of all fugitive emissions from well sites.
- Once fully implemented, EPA projects this proposed program will require routine methane monitoring at 300,000 well sites nationwide.
- Well sites with estimated emissions of less than three tons per year must promptly conduct a survey (and perform repairs as needed) to demonstrate they are free of leaks or malfunctions but are not required to undertake ongoing monitoring.
- EPA is seeking comment on whether sites in this category should be required to conduct regular monitoring for leaks if certain leak-prone equipment is present on these sites.
- EPA is co-proposing a requirement that sites with estimated emissions between three and eight tons per year be monitored semi-annually, rather than quarterly.
- Surveys must include inspections of equipment that is most prone to large leaks and malfunctions, including hatches on storage tanks and flares
EPA is seeking information about additional sources of pollution that may help the Agency further reduce methane and VOC emissions from the oil and natural gas sector, including:
- Abandoned and unplugged wells
- Opportunities to improve performance and minimize malfunctions at flares
- Pipeline “pigging” operations
- Tank truck loading operations
Of particular note to our sector, EPA is also seeking comment on:
- Regulatory alternatives that accomplish Clean Air Act objectives while minimizing significant economic impact to small businesses
- On whether the definition of hydraulic fracturing should include numeric thresholds, or if the definition should be aligned with definitions used by other federal agencies
The structure and deadlines for comments is as follows: Comments must be received on or before January 14, 2022 but will receive higher consideration if turned in by December 14, 2021.
The EPA will hold virtual public hearings on November 30 and December 1. EPA will also host a training on November 18 for Small Business Stakeholders. You can register to attend here.
For additional information about this process or to discuss options for making comments, please contact SVP Government Affairs & Counsel Tim Tarpley.
Tim Tarpley, SVP Government Affairs & Counsel, analyzes federal policy for the Energy Workforce & Technology Council. Click here to subscribe to the Council’s newsletter, which highlights sector-specific issues, best practices, Council activities and more.
