January 28, 2016
On January 19, 2016 Pennsylvania Governor Tom Wolf announced the creation of a multi-pronged plan to target and reduce methane emissions from unconventional natural gas wells, pipelines, and other sources in the Pennsylvania oil and gas sector according to a January 25, 2016 Mondaq report.
These new rules follow similar proposed rulemaking by the U.S. Environmental Protection Agency (EPA), which was announced September 18, 2015, and is expected to be finalized in June 2016.
One of the most significant proposed changes to the current regulatory scheme is the replacement of Exemption 38 with a general permit requirement specifying Best Available Technology for equipment and processes, improved record-keeping and quarterly monitoring inspections. This requirement is expected to exceed the scope of the federal rulemaking effort and could further increase the burden on industry because development of unconventional wells, wellheads, and associated equipment will now be faced with preconstruction permitting and its associated time lag and costs.
According to Gov. Wolf’s announcement, the goal of the new plan is to make Pennsylvania “a national leader in addressing climate change while supporting and ensuring responsible energy development, creating new jobs, and protecting public health and our environment.”
The Pennsylvania Department of Environmental Protection (DEP) published a Briefing Paper that was released in conjunction with Gov. Wolf’s announcement, and provides the details of the commonwealth’s proposed methane emissions reduction strategy. The DEP also hosted a webinar January 19, 2016, chaired by DEP Secretary John Quigley, to discuss the new plan.
At the webinar, Secretary Quigley estimated that 115,000 tons of methane were wasted in Pennsylvania in 2014 as the result of emissions from unconventional wells and midstream operations, and stated his hope that by reducing methane waste, the new measures will “pay for themselves.” Secretary Quigley anticipates at least a 40 percent reduction in methane emissions as the result of the new rules.The rules comprise four parts that DEP will develop and implement over the course of 2016:
- By August 2016, DEP will replace the August 2013 Category No. 38 conditional permit exemption (Exemption 38) with an Air Quality General Permit (GP) requirement for oil and gas exploration, development, and production facilities, including well pads. Among other things, the GP will require Best Available Technology for equipment and processes, improved record-keeping, and quarterly monitoring inspections.
- DEP will revise the current GP-5 for new and modified Natural Gas Compression and/or Processing Facilities to (a) incorporate Best Available Technology requirements, including a Leak Detection and Repair (LDAR) program for new sources; (b) amend the requirements for affected sources; (c) expand the applicability of GP-5 to cover sources located at natural gas transmission stations; and (d) establish more stringent requirements for affected sources.
- DEP will develop a regulation for consideration by the Environmental Quality Board that establishes stringent requirements for existing sources in the oil and gas industry.
- Working through the Pipeline Infrastructure Task Force DEP will establish Best Management Practices, including LDAR programs, to reduce fugitive methane emissions from production, gathering, processing, and transmission facilities.
What this means to you
Pennsylvania’s new methane rules may be more stringent than EPA standards. Among other things, DEP will require Best Available Technology for equipment and processes, improved record-keeping and quarterly monitoring inspections.
MIRATECH can help
Contact MIRATECH to learn about engine emission reduction solutions in gas compression applications.