Today the White House released a report outlining the administration’s interagency Strategy to Reduce Methane Emissions. A link to the document can be found below. While this plan also includes strategies to reduce agricultural methane emissions and landfill emissions, the upstream methane emissions are a large part of the report. The report refers to the forthcoming EPA white papers as well as revisions to Onshore Order No. 9 relating to venting and flaring. IPAA, which is working very closely with EPA believes their white papers will impact oil/hybrid wells, liquids unloading, pneumatics, leaks and compressors.
In addition, earlier this week IPANM held a very informative meeting with Sandra Ely, Enforcement Officer for the New Mexico Air Quality Bureau. The purpose of the meeting was to solicit comments from IPANM members on the Voluntary Environmental Self-evaluation policy. The Department is very concerned that with the new EPA SubPart OOOO requirements that companies are discovering that many facilities, particularly in the Permian, may be over the 10 ton per year limit not to have an NOI permit.
As the policy now stands, for a company to self report that a facility is over the limit and therefore needs an NOI, the proposed Voluntary Disclosure requirements. The environmental audit must be:
a. Communicated with the Department prior to commencing so that they can ensure it is systematic, periodic and objective;
b. The audit must be completely voluntary, in other words, not done to meet any other federal reporting requirement. So if you think you might be over, you need to do a parallel investigation which is systematic and objective.
c. The level of due diligence necessary for the audit will be determined at the communication meeting prior to commencing the audit. The time frame for disclosure will also be determined at the meeting prior to the audit.
d. Note that this tool is not available to companies with repeated violations of the same offense. – PLEASE comment on this provision.
Please note that this policy, although initially drafted 20 years ago, has not been enforced or used often by the department as it is meant to be an agency-wide policy. The Air Bureau is in the process of revamping this policy to apply to their issues in light of the recent discoveries. IPANM will continue to work with the Department to see if there may be a way for operators to report these increased emissions within a specified timeframe to avoid penalties. Please send your comments to this policy to Sandra Ely at Sandra.Ely@state.nm.us. If you would like to add to IPANM’s comments instead, please send them to Karin at Karin@ipanm.org by April 8th. The Department wants the comments by April 10th.
Strategy to Reduce Methane Emissions 2014-03-28
ABQ Voluntary Environmental Self-Evaluation Policy
