Ensolum has recently expanded into offering air quality consulting services. We currently have the capacity to assist local oil and gas operators with permitting, air emissions modeling, regulatory analysis, emissions reduction, and environmental data management. Now that we’ve covered the formalities, let’s dive into the latest development in the world of air quality.
WE READ THE RESEARCH
A recent LDAR (leak detection and repair) study conducted on oil & gas sites in Alberta unsurprisingly identified tanks as the largest source of emissions. Despite accounting for only 14% of detected leaks in the study, tank thief hatches and open-ended lines were responsible for 47% of total emissions. The study also revealed that implementing a routine LDAR inspection and repair program reduced site-level emissions by 46%. Additionally, once repaired, leaks typically did not reoccur, demonstrating the effectiveness of LDAR.
Researchers from Colorado State University stirred regulators in Colorado with their findings on unplugged wells. They reported that 61% of the unplugged wells they assessed were emitting methane at an average rate of 30 scf/hour, suggesting that merely shutting-in of marginal wells does not suffice to cut emissions without complete plugging.
OOOOb
The EPA’s long-awaited (or dreaded) rule, OOOOb, was published in the Federal Register on 3/8/2024. Many of the rule’s effective dates are set for 60 days after publication, which falls on 5/7/2024. Are you prepared to comply? For guidance, please see the attached link for Ensolum’s custom guidance cheat sheet.
SPEAKING OF SUPER EMITTERS…
MethaneSAT has officially launched its first three methane detection satellites. Although data from these satellites has not yet been published, we expect it to begin arriving in the next few months. MethaneSAT has partnered with Google to create a mapping platform where all the data will be made available. You can access it here.
TEXAS’ SOLUTION TO OOOOb TANKS
Texas created the LP-CERT to allow operators in the state to certify the legally & practically enforceable criteria for storage vessels under OOOOb. Operators must print and mail these certifications to the TCEQ. These can be found here.
MORE RULES? – YOU BET!
Colorado Air Quality Control Commission Updates:
Colorado’s AQCC will have consider a series of rule changes on 5/15/2024, impacting
Regulation 3 and Regulation 7. Key proposals include:
1. Monitoring Fees: Changing DI Community Monitoring Fees from going to the Air Quality
Enterprise Fund to the Stationary Source Control Fund
2. Emergency Emissions: Removing the emergency affirmative defense provision from Title V permits. Have you planned for permitting emergency emissions?
3. EJ Permitting Requirements: Updating EJ Summary requirements for construction and
operating permit applications, which includes new exemptions for certain submittals.
Federal & Tribal Land Regulations:
The BLM has finalized its Waste Prevention Rule for oil and gas production, effective
6/10/2024. This rule tightens requirements on flaring, venting, and fees. A detailed fact sheet is available here.
SEC Climate-Related Disclosures:
On 3/6/2024, the Securities and Exchange Commission (SEC) adopted rules requiring public companies to disclose Climate-Related information, including Scope 1 and Scope 2 emissions, starting in 2025. Although not yet published in the Federal Register, these rules will be effective 60 days post-publication. Access the fact sheet here.
EPA Methane Emission Charges:
The EPA has closed public comment as of 3/26/2024 on its proposed Waste Emission Charge. This charge will be applied annually to methane emissions from O&G facilities that exceed set thresholds, starting with 2024 emissions. Fees start at $900 per metric ton in 2024 and will increase to $1500 per metric ton by 2026. Further changes to the Subpart W GHG Reporting
Rules are proposed to update emission calculation methodologies. Find more information and webinar links here and here.
Proposed Revisions to PM2.5 Standards:
The EPA is proposing to revise the annual PM2.5 National Ambient Air Quality Standards
(NAAQs) from 12 ug/m3 to 9.0 – 10.0 ug/m3, while considering limits as low as 7.0 ug/m3 or as
high as 11 mg/m3. New non-attainment areas and stricter emission limits are likely to follow.
A FEW NEW UPCOMING DEADLINES
6/30/2024: The first Colorado Air Toxics Reports are due. Please note, there is no de
minimis threshold for reporting.
7/1/2024: The New Mexico Ozone Precursor Rule requirement for Compliance Database
Reporting becomes effective.
8/5/2024: Existing facilities must begin LDAR under the NM Ozone Precursor Rule.
