Underground Infrastructure - January 2023 - 11

WASHINGTONWATCH
The Environmental Protection Agency
(EPA) has once again proposed to tighten
the vise on interstate pipeline methane
emissions. Its supplemental Clean Air regulatory
proposal, in November this year,
doubles down on a never-finalized recommended
rule issued in November 2021,
which the transmission industry slammed
for unrealistic emission controls.
Now, with the new proposal, announced
while President Biden was at
the COP27 in Egypt, in November, the
EPA goes from bad to worse.
In the supplemental proposal, the
agency wants to tighten standards on wet
seal compressors even more. And just to
agitate the pipeline industry further, EPA
wants to regulate centrifugal compressors
with dry seals for the first time.
Other new control mandates, some
of which have been upgraded since the
2021 proposal, include increasing the
kinds of controllers the emission limits
apply to and eliminating an industry
standard for annual maintenance of
rod-packing in compressors.
The EPA presents no estimates of the
cost of these control requirements to
the interstate pipeline industry, nor the
extent to which they allow for methane
emission reductions compared to current
levels. This new proposal contains
stricter methane and volatile organic
chemical (VOC) emissions for the entire
oil and gas industry, as well as across
various production, transmission and
equipment segments.
It is complicated because there are
three separate sections of the Clean Air
Act that impact facilities based on when
they were put into operation: before
2011, before 2015 and those in the future
that are new or modified.
This " supplemental " proposed rule
(or upgrading of the November 2021
Stephen Barlas | Washington, D.C. Editor
EPA Ups Ante on Pipeline
Methane Emissions
proposal) covers 500 pages and touches
on provisions dealing with advanced
methane detection technologies, a new
super-emitter response program, pneumatic
controllers, pneumatic pumps, centrifugal
compressors, combustion control
devices and reciprocating compressors.
In establishing standards, the EPA,
for most part, applies a methodology
called " best system of emission reduction "
(BSER). It takes into account the
cost of achieving the specified emissions
reduction, and any non-air-quality
health and environmental impact and
energy requirement the Administrator
determines have been adequately
demonstrated.
One bit of welcome news for the industry
is that the EPA will not establish
emission standards for pipeline pigging,
though some states do have such
specifications.
Alternatives and changes
This new mega-proposal maintains the
November 2021 proposal to reduce
methane emissions from each centrifugal
compressor wet-seal fluid degassing
system by 95 percent - a standard
Kinder Morgan claimed is " unworkable
and untethered from real-world application
of such controls, which have not
been demonstrated. "
The EPA believed that to comply with
that standard, pipelines would route the
methane or VOC emission to either a
control device or a process.
In the November 2022 supplemental
proposal, the 95-percent requirement
is a potential alternative to EPA's new
" presumptive " (meaning likely choice)
standard of limiting methane and VOC
emissions from self-contained wet-seal
centrifugal compressors to less than
3 standard cubic feet per minute (scfm).
The EPA admitted that when self-contained
wet-seal compressors are operating
properly, they emit trivial amounts
(achieving greater than 99-percent control)
of methane. The EPA also recognizes
that where there is venting of any
emissions from these compressors, they
would more than likely be nondetectable
for leaks, or at a rate lower than 3 scfm.
With that in mind, EPA says it is open
to a lower numerical limit.
In its comments on the 2021 proposal,
the Interstate Natural Gas Association
of America (INGAA) argued, " EPA's
perception and estimates of wet-seal
emissions, however, are based on compressors
of a certain type and vintage
that are not representative of most wetseal
compressors in the transmission and
storage sector. "
In addition, dry seals would be regulated
for the first time and subject to
the same 3 scfm volumetric flow rate
emission limit, which EPA copied from
California's Regulation for Greenhouse
Gas Emission Standards for Crude Oil
and Natural Gas Facilities.
" In the 2021 notice, EPA noted that
emissions from dry seals are a relatively
small contributor, so the related support
documentation for adding this control requirement
will be closely reviewed, " said
Scott Yager, INGAA's vice president of
environment, " especially since past EPA
actions and voluntary programs promoted
dry-seal technology over wet seals. "
Katherine Hill, spokeswoman for
Kinder Morgan, said the company has
no comment on the recent supplemental
proposal beyond the concerns it voiced
about the proposed November 2021 rule.
The new requirement to control dryseal
emissions will undoubtedly be controversial,
as will many other aspects of
the supplemental proposal.
UndergroundInfrastructure.com | JANUARY 2023 11
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Underground Infrastructure - January 2023

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