Underground Construction - November 2019 - 13

try from compliance with 2012 and 2016
Clean Air Act standards related to volatile
organic chemicals (VOC) and greenhouse
gases, chiefly methane. The Obama EPA adopted revised standards for VOCs for the oil
and gas sector in 2012. At the same time,
EPA required transmission and storage facilities to adhere to those standards, which
affect mostly controllers and compressors.
In 2016 the agency extended Clean Air Act
standards to methane emissions.
If the Trump EPA proposed rule issued
in September becomes final, the decision
would cancel the transmission industry's
inclusion in the "oil and gas" category
eliminating any need to comply with
either VOC or methane emission restrictions. However, the agency broached the
possibility of not going forward with that
action. The Obama administration made
the decision in 2012 to bring transmission
companies into the oil and gas category,
arguing it was "interpreting" a 1979 ruling
that was "broad enough" to include transmission companies, even though they were
not specifically mentioned in that 1979
document.
In 2016, INGAA asked for a two-year
stay of that rule citing provisions affecting
fugitive emission requirements at compressor stations. These so-called "delay of
repair" requirements are associated with
repairing leaks at compressor stations and
obligations related to third-party equipment, and altering the phase-in periods for
these requirements.
Most of those objected-to provisions
went into effect. However, in 2018, the
EPA announced it was reconsidering three
issues, one of which was fugitive emission.
In its December 2018 response, INGAA
submitted comments asking for numerous
changes to the 2016 final rule including
those on leak detection and repair and,
for example, revising the delay of repair
provisions to eliminate the requirement
to complete a repair if a planned vent
blowdown occurs.
The three 2018 proposed changes, including the one on fugitive emissions, were
never finalized by the Trump EPA.
But the September 2019 proposed rule
would give INGAA everything it wanted
from its December 2018 request, and much
more. Any final rule removing transmission
companies from the oil and gas industry,
for the purposes of clean air standards,

would obviously eliminate all requirements
on gas companies imposed by both the
2012 and 2016 final rules. The EPA did
offer an alternative proposal that would
allow it to eliminate methane restrictions
but maintain VOC emission standards for
the transmission industry.
Patrick Creighton, a spokesman for
INGAA, said the group will be filing comments on the proposed rule. Those are due
at the end of November.
Meanwhile, environmental groups have

taken issue with the proposal, which would
relieve the entire energy industry from
having to monitor and limit greenhouse
gas emissions The VOC limits would still
be in effect for all sectors, except interstate
gas transmission companies and storage
companies. According to Sierra Club
Executive Director Michael Brune, "This
proposal is a blatant attempt to give oil and
gas companies yet another free pass to release as much harmful air pollution as they
want while the public pays the price." *

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UConOnline.com | NOVEMBER 2019

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Underground Construction - November 2019

Table of Contents for the Digital Edition of Underground Construction - November 2019
