Underground Infrastructure - January 2023 - 12

Washington Watch
For example, the " Super Emitt er "
program allows not only governmental
bodies, but " third parties, " to identify
a company with a methane emission
exceeding 100 kgs/hour - although an
unusual event, per the EPA - and, therefore,
a target for immediate redress.
To detect such super emissions, EPA
would allow surveillance of oil and gas
operations by third parties using remote-sensing
aircraſt , mobile monitoring
platforms, or satellites. Requiring
EPA approval, these notifi ers could be
any third party, such as technology vendors,
industry, researchers, nonprofi t
organizations, or others demonstrating
technical expertise as described.
Digesting 500 pages
Matt hew Hite, vice president of government
aff airs for GPA Midstream
Association, says his group is still
combing through the 500-page Federal
Register notice.
" Off the top of my head, we weren't
thrilled with the third-party enforcement
portion of it, " he stated.
Th e EPA is considering a process
of disqualifying any third party that a
pipeline can prove made " meaningful,
demonstrable errors " in three notices at
the same site. EPA does not plan to review
third-party notifi cations to energy
companies. Claiming it has done its due
diligence in certifying those parties, the
Super-Emitt er " fi nder squad " will presumably
make legitimate notifi cations.
When an energy company is notifi ed
by a third party of a super emission, EPA
proposes requiring the owner or operator
to initiate root-cause analysis and
corrective actions within fi ve calendar
days, and complete corrective actions
within 10 days.
Th e EPA does not alter its 2021 proposal
of a VOC and methane emission
rate of zero for pneumatic controllers
(continuous bleed and intermitt ent
vent). Leaking controllers would have to
be replaced over a two-year period.
However, it does make changes,
including two specifi c types of natural-gas-driven
controllers that were proposed
to be excluded from the aff ected
facility defi nition: (1) controllers where
the emissions are collected and routed
to a gas-gathering fl ow line or collection
system to a sales line, used as an onsite
fuel source or another useful purpose
that a purchased fuel or raw material
would; and (2) self-contained natural gas
pneumatic controllers.
Another diff erence is that, in 2021,
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Wherever extensive corrosion conditions exist, the
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12 JANUARY 2023 | UndergroundInfrastructure.com
EPA wanted to regulate controllers individually.
Now it defi nes a " facility " as
the collection of all the natural gas-driven
pneumatic controllers at a site, since
most zero-emissions measures for these
controllers are site-wide solutions.
INGAA argued that pneumatic controllers
used in natural gas transmission
and storage should be exempt from regulation
because they are not a signifi cant
contributor of methane. EPA turned a
deaf ear and kept the zero-emission standard
for the sector in the 2022 supplemental
proposal.
Th e new standard for rod-packing
maintenance on reciprocating compressors
is also gett ing INGAA's att ention.
EPA appears to ditch the current annual
monitoring schedule (by fl ow rate measurements)
and replace it with a standard
of performance of 2 scfm, based on
8,760 hours of operation. In an apparent
gesture of fl exibility, the 2022 proposal
allows pipelines to repair rod packing to
keep emissions below 2 scfm, opposed to
requiring complete replacement.
EPA also off ered an option, in 2021, of
routing rod-packing emissions via a closed
vent system, if done " under negative pressure. "
Th e 2022 supplemental eliminates
the negative-pressure requirement.
Instead of imposing the 2-scfm-emissions
limit as the sole means of control,
INGAA wants the EPA to keep the annual
monitoring obligation, as an alternative.
" INGAA strongly recommends that
EPA retain both options for added fl exibility,
with the operator selecting the
preferred approach, " Yager explained. UI
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Underground Infrastructure - January 2023

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