Friday, May 22, 2020

EQB Invites Comments On Regulations Controlling VOCs/Methane From Existing Oil, Gas Operations

The Environmental Quality Board is inviting comments on a proposed regulation to control methane emissions from existing oil and gas operations by setting volatile organic compound emission standards. (May 23 PA Bulletin notice)
DEP estimates the regulation will reduce methane emissions from oil and gas operations by 75,000+ tons per year and VOC emissions by more than 4,400 tons.  Read more here.
Virtual Hearings
The EQB has scheduled three virtual public hearings on the regulation for June 23 at 6:00 p.m., June 24 at 2:00 p.m. and June 25 at 6:00 p.m.
Persons wishing to present testimony at a hearing must contact Jennifer Swan for the Department and the Board, at either 717-783-8727 or a minimum of 24 hours in advance of the hearing to reserve a time to present testimony.
Information on accessing the hearing will be posted on the Environmental Quality Board webpage.
The deadline for public comments is July 27.  Comments may be submitted through DEP’s eComment webpage - where you can view all comments submitted, by email to: or in writing to Environmental Quality Board, P.O. Box 8477, Harrisburg, PA 17105-8477.
The approach used in the regulation is based on a federal Control Technique Guideline for oil and gas facilities which will be used to develop a RACT standard.  RACT is defined as the lowest emission limitation that a particular source is capable of meeting with economically feasible, reasonably available emissions control technology.
The new regulations would require oil and gas operators that produce above a certain threshold to use leak detection and repair (LDAR) equipment to identify (and fix) leaks, as well as use other equipment designed to reduce emissions.
Generally, the regulation calls for a 95 percent reduction in VOC emissions, however, some equipment-specific requirements call for less or more.  For example, natural gas processing plants are required to have zero VOC emissions.
DEP estimates there are approximately 435 midstream compressor stations, 120 transmission compressor stations and 10 natural gas processing facilities whose owners and operators may be subject to the proposed VOC emission reduction measures, work practice standards, and reporting and recordkeeping requirements.
In addition, an estimated 8,403 unconventional natural gas wells, as 303 of the 71,229 conventional natural gas wells that are above the 15 barrel of oil equivalent per production threshold would be covered by the regulation.
DEP consulted with the Air Quality Technical Advisory Committee, the Small Business Compliance Advisory Committee and the Citizens Advisory Council in the development of this proposed rulemaking.
Copies of the entire regulatory package are available-- Executive Summary; Preamble; Annex A -The Regulation; Regulatory Analysis Form; Citizens Advisory Council Letter June 18, 2019Small Business Compliance Advisory Committee Letter April 17, 2019; Air Quality Technical Advisory Committee Letter April 11, 2019.
New Reactions
Here are fresh statements issued on the proposed VOC/methane control regulation.
Dan Grossman, Senior Director of State Advocacy, Environmental Defense Fund issued a statement on the regulation-- “Gov. Wolf has demonstrated clear leadership by moving this rulemaking forward. Our analysis found that Pennsylvania oil and gas operators emit more than one million tons of methane annually. Cutting methane pollution from existing oil and gas sources is critical to meeting our climate goals. The Department of Environmental Protection should strengthen the draft rule to addresses emissions from across the oil and gas supply chain – including low-producing wells that are responsible for half of all emissions statewide.”
EDF said DEP should:
-- Remove the exemption for low-producing wells that, in aggregate, generate a significant amount of harmful pollution in Pennsylvania; and
-- Eliminate the provision that relieves operators of their responsibility to conduct frequent inspections of equipment simply because previous inspections did not reveal significant leaks.
Davitt Woodwell, President, PA Environmental Council, said--
“Given that natural gas will remain a large part of Pennsylvania’s electric generation for the foreseeable future, we need to ensure that we don’t lose the progress we've made in reducing carbon emissions. One way that that can happen is through fugitive emissions from the gas supply chain. This rulemaking moves us closer to a sustainable and economically viable energy portfolio by holding producers to a reasonable standard that can be met at little or no cost to them.”
“This rule demonstrates significant progress in addressing the climate crisis, but it also includes loopholes for the oil and gas industry that would leave about half of all of its climate-warming methane pollution unchecked,” said Joseph Otis Minott Esq., Executive Director and Chief Counsel of Clean Air Council. “We can only achieve Gov. Wolf’s climate goals with a strong final rule without loopholes for the oil and gas industry.” 
“We will be remembered for how we used this opportunity to make an impact on climate change. Given the extent of the methane problem in our Commonwealth, we appreciate Gov. Wolf moving forward with this important rulemaking," said Steve Hvozdovich, Pennsylvania Campaigns Director for Clean Water Action. "We must exude the type of environmental leadership the severity of this climate crisis calls for by strengthening the regulations and closing the loophole for low-producing wells."
“Unchecked methane is detrimental to public health,” said Alison L. Steele, Executive Director, Southwest Pennsylvania Environmental Health Project. “It contributes heavily to climate change, which in turn results in more dangerous floods, fires, heatwaves, smog, and insect-borne diseases, such as West Nile Virus and Lyme disease. Specific to human health, methane releases typically include toxic compounds, such as benzene and formaldehyde, that raise the risk of heart problems, birth defects, and cancers. The extraction and transportation of methane produces fine particles that induce or worsen asthma and other respiratory issues. Exposure to this pollution may also put people at higher risk of developing more severe symptoms from infectious lung diseases, like COVID-19. We applaud Gov. Wolf's efforts to cut methane emitted from existing oil and gas facilities and urge the PA DEP to adopt strong methane-reduction rules.”
“Pennsylvania's oil and gas industry has a problem with methane and associated toxic air pollution, and Earthworks’ field investigations show that no part of the industry is immune,” said Earthworks’ Pennsylvania and Ohio Field Advocate Leann Leiter. “If this new rule is to be successful Gov. Wolf and the DEP must ensure its enforcement so that polluters are no longer given a free pass to hurt health and climate."
“As a mother of two children living with a natural gas well pad in my community, strong pollution protections are important to me – more so now as we face a national pandemic,” said Vanessa Lynch, Field Organizer, Moms Clean Air Force. “Cutting oil and gas methane pollution will help improve air quality and public health and reduce the impacts of the climate crisis. Pennsylvania’s children deserve a clean and healthy environment to live, learn, and play.”
“This is a critical step to address one of the most prevalent, pernicious types of pollution from the fracking process--climate pollution," said PennEnvironment Executive Director David Masur. "From cradle-to-grave, we know that the web of fracking and fracking infrastructure puts our health, environment, and planet at risk. These proposed regulations are a crucial first step to reining in global warming emissions from oil and gas drilling in Pennsylvania." 
"In light of the federal government’s inaction on and disregard for the climate crisis, it’s more important than ever that Pennsylvania do its part to cut its carbon pollution,” said Rob Altenburg, director of the PennFuture Energy Center. “Methane is responsible for 25 percent of the man-made global warming we are experiencing today, so we thank the Department of Environmental Protection for doing its part to combat the climate crisis by moving forward with this rule.”
"Air emissions from the oil and gas industry threaten the health of our families and the future of our climate," said Sierra Club Senior Campaign Representative Kelsey Krepps. "We applaud Governor Wolf for moving this commonsense standard forward to limit air pollution and protect Pennsylvanians."
Rev. Mitch Hescox, President and CEO, Evangelical Environmental Network -- “Methane and Volatile Organic Compounds (VOCs) pose a severe health threat to Pennsylvania’s children. Over 90% of peer reviewed medical research links preterm births, birth defects and other serious medical conditions to methane leaks and fugitive emissions. That’s why over 100,000 pro-life Christians in Pennsylvania have been calling on Governor Wolf to address this threat to our unborn and newborn babies. Thankfully, the Governor heard our concerns and is advancing this new standard to reduce emissions from existing wells. This move will help to defend the health and lives of our children. We will be sure our voices are heard again during this public comment period as we seek to strengthen protections.”
David Jenkins, President, Conservatives for Responsible Stewardship-- “We’re pleased to see DEP is moving forward with rules to limit waste and pollution from existing oil and gas operations. Industry should take the long view, and recognize that a strong final methane rule that protects our health, safeguards the climate, reduces waste, and bolsters responsible energy development, will help ensure its future. As the public comment period opens, CRS and our Pennsylvania members will advocate to strengthen the rule and sure that it addresses emissions from across the oil and gas supply chain.”
Kate Hoit, State Director, Vet Voice Foundation-- “We must address Pennsylvania’s million ton methane problem to both safeguard our climate and improve our energy security. A strong final will help tackle the climate crisis, which military experts have recognized as a national security threat. Vet Voice Foundation and our veterans thank Gov. Wolf for continuing to be a national leader on climate.”
Michael Kovach, Policy Director, Pennsylvania Farmers Union-- “Governor Wolf should be commended for moving forward with this rulemaking. A strong, comprehensive rule will benefit farmers, who are facing more extreme weather, including severe storms and droughts, intensified by climate change. By reducing wasteful leaks and increasing efficiency, we can ensure more responsible energy development and help royalty owners achieve a greater return. We will be advocating that a strong final rule should be adopted in the upcoming public comment period.”  
Isaac Brown, Executive Director, Center for Methane Emissions Solutions-- The Center for Methane Emissions Solutions applauds Governor Wolf for taking this important step forward to cutting methane waste and pollution. That is common sense for our economy and environment. We look forward to constructively engaging in this rulemaking and advocating for a comprehensive approach to addressing leaks across the oil and gas supply chain. Our members have the technological know-how to provide cost-effective solutions to cut methane and help achieve the state’s climate goals.
Earlier Reactions
Marcellus Shale Coalition president David Spigelmyer released this statement in response to the December 17 action by the Environmental Quality Board to approve regulations to control methane emissions from existing oil and gas operations for public comment--
“Our industry is focused on ensuring methane, the product we produce and sell, as well as related emissions are effectively and safely managed.
“To continue to build upon our air quality-related successes, we’re enhancing best practices, utilizing new technologies and collaborating as an industry around these shared environmental and business goals, all while pushing record production levels.
“We do, however, have concerns about potential costs as well as DEP’s timing given ongoing federal regulatory activity associated with existing source emissions. Rather than creating more regulatory uncertainty, DEP should delay any regulatory proposals until federal rules are finalized.”
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[Posted: May 22, 2020] PA Environment Digest

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