Comments on epa’s proposed amendments to methane and voc emissions standards due dec. 17 – the texas lawbook k gas station jobs


• Recognize that some state fugitive emissions programs are equivalent, including the Texas leak detection and repair program for well sites, although owners and operators would be required to give the EPA 90 days prior notification of their intent to rely on such a state standard. a level physics electricity equations The EPA also proposed to recognize the equivalency of the California, Colorado, Ohio, Pennsylvania and Utah fugitive emissions standards programs for either well sites or compressor stations, or in some cases both. gas explosion in texas The EPA’s state program equivalency analyses are available in the agency’s Memorandum dated April 12.

o A “modification” of a well site for purposes of the fugitive emissions requirements includes removal of all major production and processing equipment from the site, triggering fugitive emissions monitoring at the tank battery to which that well produces, but also allowing monitoring at the wellhead to cease once that equipment is removed.

• Allow an in-house engineer with appropriate expertise, as opposed to only a licensed professional engineer, to make the required certifications for closed vent system design and operation and for the technical infeasibility determinations that justify the exemption of certain pneumatic pumps from the well site pneumatic pump requirements.

• Allow an owner or operator – or, in recognition of emerging technologies, a manufacturer, vendor or trade association together with an owner or operator – to apply for an alternative means of emissions limitations as a substitute for the NSPS Subpart OOOOa work practice standards for multiple sites (not only on a site-by-site basis), although requiring that site-specific information be submitted with the application.

Notably, the EPA expressed ongoing concerns in this rulemaking action about the compliance of storage vessels with NSPS Subpart OOOOa. gas nozzle keeps stopping First, the agency stated its concern about uncontrolled emissions from tank thief hatches and pressure relief valves due to inappropriately sized or inadequately designed closed vent systems. gas x directions Second, it expressed surprise about the low number of storage vessels that operators have determined to be affected facilities under NSPS Subpart OOOOa. electricity in indian states The EPA reiterated the requirement that the VOC emissions calculations for storage vessel affected facility determinations must be made on a per-storage-vessel basis – for example, averaging of total potential VOC emissions across storage vessels is only appropriate when certain operational configurations are utilized.

James C. Morriss III serves as Thompson & Knight’s Austin Office Leader. He focuses his practice on environmental permitting; compliance counseling; facility siting, including wetlands and endangered species work; legislative lobbying; and administrative and judicial litigation before local, state, and federal environmental agencies and state and federal courts.

Ashley T. K. Phillips is a partner in Austin and focuses her practice on environmental regulatory matters. gas 1940 hopper Her experience includes compliance counseling; environmental management system development; environmental, health, and safety auditing; environmental risk assessment; environmental due diligence; advising on environmental matters in corporate and commercial transactions; handling administrative enforcement actions; and working with private and governmental (including federal, state, and local) entities to develop and implement collaborative environmental solutions.