Underground Construction - October 2020 - 11

* Minimize emissions during maintenance,
repair and replacement of pipelines.
* Replace rod packing on all transmission
and storage reciprocating compressors.
* Conduct leak surveys at all memberowned and operated transmission, and
transmission and storage, compressor
stations by 2022, and at all natural gas
storage wells owned and operated by
INGAA member companies by 2025.
* Transparently report methane
emissions."
In welcoming the August 2020 final
rule, the American Petroleum Institute
(API) made the same point about methane
reductions over the past decade. It said
methane emission rates from five of the
largest producing regions across the U.S.
have fallen more than 60 percent from
2011 to 2018 - even as production in
those regions has increased dramatically.
The production industry's drive to lower
VOC emissions, which remains required
under the Oil & Gas NSPS, results in those
emissions reductions.
"The Trump administration's attempt
to eliminate these sensible methane
standards is fundamentally flawed," said
Krupp in a statement. "Like so many
other administration rollbacks that have
already been rejected by the courts, this
one ignores the science, the public health
impacts and the low-cost solutions we have
at hand. These sensible pollution controls
have been working to protect Americans
since 2016. Investors, states, community
groups and even leading oil and gas
producers have all called on the EPA to
retain and strengthen methane safeguards.
The administration has no scientific or
public health basis for taking this action,
and EDF will forcefully oppose it in court."
In eliminating transmission pipelines
from the oil and gas category, the EPA
looked back to a 1971 "listing" by the EPA
of the sectors in the oil and gas category.
That listing did not explicitly include
transmission pipelines. The Obama administration, in 2012, in effect interpreted
the 1971 listing as being broad enough to
include pipelines, even though they were
not explicitly included. The August 2020
final EPA rule said the oil and gas sector

rule was wrong in 2012 because the Obama
administration did not meet a statutory
requirement to determine whether pipeline
emissions contribute significantly to the
endangerment of public health or welfare.
The EPA did make an affirmative,
"significant contribution and endanger-

ment" analysis regarding methane in 2016,
which the August 2020 final rule said was
erroneous because it included transmission
emissions and lacked an "intelligible standard or threshold for determining when an
air pollutant contributes significantly to
dangerous air pollution." *

Times like these don't come with instructions.
They challenge us to our inner core. Good thing is,
you don't need instructions. You know what to do.
You've worked for everything you've got, and you're
not going to stop now. Our new LiuGong Partnership
Program offers lower machine pricing, flexible payment
rates and terms, and rental and leasing programs
that will help your bottom line.
We want you running stronger
then ever. Getting work done,
just like you always have.

TOUGH WORLD.
TOUGH EQUIPMENT.

Learn more at LiuGongNA.com

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Underground Construction - October 2020

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