Last Monday, the members of the IPANM Air Quality Committee and I submitted comments to the EPA, Office of Planning, on the five whitepapers issued by that Agency. The whitepapers, which came about at the request of the President in his March 2014 Climate Change: Strategy to Reduce Methane Emissions Report, sought to create a technical basis for reducing methane emissions in the oil patch from compressors, pneumatic devices, completions from hydraulically fractured oil wells, and during the liquids offloading process. The final whitepaper sought to review the “science” on methane leaks at oil and gas facilities.

The EPA whitepapers were meant to be a technical review of the existing studies in order to give EPA a “robust understanding” of the issues, but in reality it was nothing more than a data dump from carefully selected studies that used mostly modeling and not actual measurement from the field. The one study that did use some measurements was completed by UT professors, but it only looked at oil and gas facilities in shale plays. The main point raised by IPANM in our responses to the EPA was that the studies on methane emissions were flawed as they had very small samples, huge and extremely flawed extrapolation methodology and the whitepapers relied on studies completed by biased entities. In every whitepaper, there was heavy reliance on a study of 22 locations that was commissioned by the Environmental Defense Fund. On every panel doing a “peer review” of the whitepapers, there was a person from the Environmental Defense Fund. A second point made by IPANM was that the EPA should not rush this process and should learn from the data submitted by industry to the recent NSPS OOOO regulations.

On June 2nd, IPANM also submitted lengthy comments to the BLM Venting & Flaring Public Outreach Powerpoint presentation. This initiative, also the result of the President’s March Climate Change Report, was intended as a first step towards developing regulations on reducing methane emissions from compressors, liquid unloading, hydraulically fractured natural gas wells, leaks and pneumatic devices. Note that the subject matter of these regulations are nearly identical to the issues reviewed by the EPA in their whitepapers, but the BLM claims it has the authority to force regulations on methane emissions under a legal theory of prevention of waste and royalty collections. IPANM strongly contested this assertion in our comments.

According to the President’s Climate Change Strategy to Reduce Methane Emissions Report, both the EPA and the BLM are to have all rules and regulations on these issues completed by the end of 2016.

All of the comments submitted to the EPA are available below:

IPANM Leaks Comments to EPA
IPANM Compressors Comments to EPA
IPANM Completions Hydraulically Fractured Oil Wells Comments to EPA
IPANM Unloading Comments to EPA
IPANM Pneumatic Devices Comments to EPA

Today, IPANM submitted comments to the BLM on their proposed Venting & Flaring policy changes which were mandated by the Whitehouse in its March 2014 Climate Strategy for Methane Reductions report. I have attached a copy of the comments to this email for you to read at your leisure. The IPANM comments will be distributed to the EPA as their pending whitepapers on methane reductions strategies are on the same topics. IPANM will be submitting comments to the whitepapers as well.

At the IPANM air quality workshop “UP the PIPE,” which was held last week in Albuquerque, the participants had the opportunity to learn about NSPS SubPart OOOO, the Whitehouse Climate Change Strategy, the BLM Venting plan and the EPA’s plans to further regulate methane emissions. We also had several sessions on the newly implemented Colorado Venting rules. We heard from some excellent experts from Trinity Consulting and TRC Companies as well as the regulators from EPA, BLM, NMED and CO. All the materials from the workshop are now on the IPANM website. The comments to the BLM and the EPA will be included at www.ipanm.org on the Regulatory tab as we submit them.

All the work to digest the technical papers and draft comments could not have been done without the extreme time and effort of IPANM Air Quality Committee members Bruce Stubbs, Kyle Alpers, Ed Hasely and Board President Richard Gilliland! Please thank these members for me when you see them. As always, if you have any questions or comments let us know.

BLM Venting & Flaring Comments by IPANM

IPANM held a two-day seminar on air quality issues on June 2-3, 2014 at the Sandia Resort and Casino. Below are links to the presentation information from the seminar:

CO & NM Air Issues
EPA Presentation, Comments, Documents
Subpart 0000 & Tribal
BLM Presentation and Comments
Overview and Obama Plans

June 26, 2014
IPANM Leaks Comments to EPA
IPANM Compressors Comments to EPA
IPANM Completions Hydraulically Fractured Oil Wells Comments to EPA
IPANM Unloading Comments to EPA
IPANM Pneumatic Devices Comments to EPA

BLM Venting & Flaring Comments by IPANM

This spring, operators had to report their emissions from storage tanks and various other facilities to the EPA under SubPart OOOO. The BLM is asking for comments to their venting and flaring proposed policy. The EPA released five white papers on reducing methane emissions from various facilities in the oil patch with comments due in June. The NMED has also asked for comment on their voluntary disclosure policy, and they finalized the GCP-6.

Are you confused and frustrated with the reporting requirements for operators when it comes to air quality issues?

On June 2 – 3rd, IPANM will be holding an educational workshop on federal and state air quality regulations, policies and proposals affecting oil and gas producers in New Mexico. The event will be held at Sandia Resort & Casino from 1pm June 2 to 4pm June 3.

On June 2, Trinity Consulting will present and educate members on quantifying and reporting air emissions under SubPart OOOO, Part W (greenhouse gases) and Indian lands. There will be discussion on the proposed venting policies from both EPA and BLM. June 2nd will be an industry-only day to openly learn, discuss and question the industry experts about the air issues.

On June 3rd, the government representatives have been invited to speak on their respective agency proposals. There will be opportunity for questions and discussions. NMED will discuss the development and use of the GCP-6 permit, the requirements for an NOI permit and the use of the current voluntary disclosure policy. The BLM will speak about their proposed venting policy, which they are currently shopping around the country in stakeholder meetings. Finally, the EPA (invited) representative will speak to the development and implementation of the policies in the recently released white papers on reduction of methane emissions pursuant to the President’s newest Climate Change policy.

We will also be sending all meeting registrants the seminar materials digitally prior to the event to print out. After the event, IPANM will have a link on our website much like we have for the ONRR issues.

In discussions with our Board members, this issue has been one of the most frustrating for operators. Don’t miss this workshop and find out that you later missed a deadline with the NMED or the EPA.

Registration Form