January 2023 Vol. 78 No. 1

Washington Watch

Washington Watch: EPA Ups Ante on Pipeline Methane Emissions

Stephen Barlas | Washington, D.C. Editor 

(UI) — The Environmental Protection Agency (EPA) has once again proposed to tighten the vise on interstate pipeline methane emissions. Its supplemental Clean Air regulatory proposal, in November this year, doubles down on a never-finalized recommended rule issued in November 2021, which the transmission industry slammed for unrealistic emission controls. 

Now, with the new proposal, announced while President Biden was at the COP27 in Egypt, in November, the EPA goes from bad to worse. 

In the supplemental proposal, the agency wants to tighten standards on wet seal compressors even more. And just to agitate the pipeline industry further, EPA wants to regulate centrifugal compressors with dry seals for the first time. 

Other new control mandates, some of which have been upgraded since the 2021 proposal, include increasing the kinds of controllers the emission limits apply to and eliminating an industry standard for annual maintenance of rod-packing in compressors. 

The EPA presents no estimates of the cost of these control requirements to the interstate pipeline industry, nor the extent to which they allow for methane emission reductions compared to current levels. This new proposal contains stricter methane and volatile organic chemical (VOC) emissions for the entire oil and gas industry, as well as across various production, transmission and equipment segments. 

It is complicated because there are three separate sections of the Clean Air Act that impact facilities based on when they were put into operation: before 2011, before 2015 and those in the future that are new or modified. 

This “supplemental” proposed rule (or upgrading of the November 2021 proposal) covers 500 pages and touches on provisions dealing with advanced methane detection technologies, a new super-emitter response program, pneumatic controllers, pneumatic pumps, centrifugal compressors, combustion control devices and reciprocating compressors. 

In establishing standards, the EPA, for most part, applies a methodology called “best system of emission reduction” (BSER). It takes into account the cost of achieving the specified emissions reduction, and any non-air-quality health and environmental impact and energy requirement the Administrator determines have been adequately demonstrated. 

One bit of welcome news for the industry is that the EPA will not establish emission standards for pipeline pigging, though some states do have such specifications. 

Alternatives and changes 

This new mega-proposal maintains the November 2021 proposal to reduce methane emissions from each centrifugal compressor wet-seal fluid degassing system by 95 percent – a standard Kinder Morgan claimed is “unworkable and untethered from real-world application of such controls, which have not been demonstrated.” 

The EPA believed that to comply with that standard, pipelines would route the methane or VOC emission to either a control device or a process. 

In the November 2022 supplemental proposal, the 95-percent requirement is a potential alternative to EPA’s new “presumptive” (meaning likely choice) standard of limiting methane and VOC emissions from self-contained wet-seal centrifugal compressors to less than 3 standard cubic feet per minute (scfm). 

The EPA admitted that when self-contained wet-seal compressors are operating properly, they emit trivial amounts (achieving greater than 99-percent control) of methane. The EPA also recognizes that where there is venting of any emissions from these compressors, they would more than likely be nondetectable for leaks, or at a rate lower than 3 scfm. 

With that in mind, EPA says it is open to a lower numerical limit. 

In its comments on the 2021 proposal, the Interstate Natural Gas Association of America (INGAA) argued, “EPA’s perception and estimates of wet-seal emissions, however, are based on compressors of a certain type and vintage that are not representative of most wet-seal compressors in the transmission and storage sector.” 

In addition, dry seals would be regulated for the first time and subject to the same 3 scfm volumetric flow rate emission limit, which EPA copied from California’s Regulation for Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities. 

“In the 2021 notice, EPA noted that emissions from dry seals are a relatively small contributor, so the related support documentation for adding this control requirement will be closely reviewed,” said Scott Yager, INGAA’s vice president of environment, “especially since past EPA actions and voluntary programs promoted dry-seal technology over wet seals.” 

Katherine Hill, spokeswoman for Kinder Morgan, said the company has no comment on the recent supplemental proposal beyond the concerns it voiced about the proposed November 2021 rule. 

The new requirement to control dry-seal emissions will undoubtedly be controversial, as will many other aspects of the supplemental proposal. 

For example, the “Super Emitter” 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 aircraft, mobile monitoring platforms, or satellites. Requiring EPA approval, these notifiers could be any third party, such as technology vendors, industry, researchers, nonprofit organizations, or others demonstrating technical expertise as described. 

Digesting 500 pages 

Matthew Hite, vice president of government affairs 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. 

The 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 notifications to energy companies. Claiming it has done its due diligence in certifying those parties, the Super-Emitter “finder squad” will presumably make legitimate notifications. 

When an energy company is notified by a third party of a super emission, EPA proposes requiring the owner or operator to initiate root-cause analysis and corrective actions within five calendar days, and complete corrective actions within 10 days. 

The EPA does not alter its 2021 proposal of a VOC and methane emission rate of zero for pneumatic controllers (continuous bleed and intermittent vent). Leaking controllers would have to be replaced over a two-year period. 

However, it does make changes, including two specific types of natural-gas-driven controllers that were proposed to be excluded from the affected facility definition: (1) controllers where the emissions are collected and routed to a gas-gathering flow 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 difference is that, in 2021, EPA wanted to regulate controllers individually. Now it defines 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 significant contributor of methane. EPA turned a deaf ear and kept the zero-emission standard for the sector in the 2022 supplemental proposal. 

The new standard for rod-packing maintenance on reciprocating compressors is also getting INGAA’s attention. EPA appears to ditch the current annual monitoring schedule (by flow 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 flexibility, the 2022 proposal allows pipelines to repair rod packing to keep emissions below 2 scfm, opposed to requiring complete replacement. 

EPA also offered an option, in 2021, of routing rod-packing emissions via a closed vent system, if done “under negative pressure.” The 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 flexibility, with the operator selecting the preferred approach,” Yager explained.

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