Tag Archives: NSPS

EPA Proposes Updates to Air Regulations for Oil and Gas Industry

August 31, 2019

 

The updates to air regulations intend to remove redundant requirements and reduce compliance burdens where environmentally appropriate.

The U.S. Environmental Protection Agency (EPA) proposed updates to the oil and natural gas industry national standards. The proposal intends to remove regulatory duplication while maintaining health and environmental regulations on oil and gas sources that the agency considers appropriate. The proposal is the result of EPA’s review of the 2016 New Source Performance Standards (NSPS) for the oil and natural gas (O&G) industry conducted in response to Executive Order 13783 – Promoting Energy Independence and Economic Growth. The goal was to review existing regulations that could potentially “burden the development or use of domestically produced energy resources,” including oil and natural gas.

The resulting regulatory impact analysis from EPA estimates that the proposed amendments could save the O&G industry $17-$19 million a year, for a total of $97-$123 million from 2019 through 2025.

“EPA’s proposal delivers on President Trump’s executive order and removes unnecessary and duplicative regulatory burdens from the oil and gas industry,” said EPA Administrator Andrew Wheeler. “The Trump Administration recognizes that methane is valuable, and the industry has an incentive to minimize leaks and maximize its use. Since 1990, natural gas production in the United States has almost doubled while methane emissions across the natural gas industry have fallen by nearly 15%. Our regulations should not stifle this innovation and progress.”

In its primary proposal, the agency is proposing to remove sources in the transmission and storage segment of the O&G industry from regulation. These sources include transmission compressor stations, pneumatic controllers, and underground storage vessels. The agency is proposing that the addition of these sources to the 2016 rule was not appropriate, noting that the agency did not make a separate finding to determine that the emissions from the transmission and storage segment of the industry cause or significantly contribute to air pollution that may endanger public health or welfare.

The primary proposal also would rescind emissions limits for methane, from the production and processing segments of the industry; keeping emissions limits for ozone-forming volatile organic compounds (VOCs). These sources include well completions, pneumatic pumps, pneumatic controllers, gathering and boosting compressors, natural gas processing plants and storage tanks. The controls to reduce VOCs emissions also reduce methane at the same time, so separate methane limitations for that segment of the industry are redundant.

In an alternative proposal, EPA would rescind the methane emissions limitations without removing from regulation any sources from the transmission and storage segment of the industry.

The agency also is seeking comment on alternative interpretations of EPA’s legal authority to regulate pollutants under section 111(b)(1)(A) of the Clean Air Act.

This proposal is in addition to a September 2018 technical action that proposed targeted improvements to help streamline implementation, reduce duplication of EPA and state requirements, and significantly decrease unnecessary burdens on domestic energy producers. EPA is currently reviewing comments received on that technical package and expects to issue a final rule in the upcoming months.

EPA will take comment on the proposal for 60 days after its publication in the Federal Register, and will hold a public hearing. EPA will announce details of the hearing shortly.

More information, including a pre-publication version of the Federal Register notice and a fact sheet, is available at https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry

Link to the proposal: https://www.epa.gov/sites/production/files/2019-08/documents/frn_oil_and_gas_review_2060-at90_nprm_20190828revised_d.pdf

Link to fact sheet: https://www.epa.gov/sites/production/files/2019-08/documents/fact_sheet._proposed_amendments_to_nsps_for_oil_and_natural_gas_industry.8.28.19.pdf

 

Air Monitoring at SCS Engineers / O&G Services

 

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: NSPS

EPA Proposed Changes to NESHAP – Comments Due by September 12, 2019

August 8, 2019

Information collection provisions are best assured of consideration if the Office of Management and Budget (OMB) receives a copy of your comments on or before August 28, 2019.

The U.S Environmental Protection Agency (EPA) is proposing amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP): Municipal Solid Waste (MSW) Landfills source category. The EPA is proposing decisions concerning the residual risk and technology review (RTR). The EPA is also proposing amendments to correct and clarify regulatory provisions related to emissions during periods of startup, shutdown, and malfunction (SSM); revise wellhead temperature and pressure operational standards and corrective action to improve system control effectiveness and provide compliance flexibility; reorganize rule text to incorporate provisions from the new source performance standards (NSPS) within this subpart; and add requirements for electronic reporting of performance test results.

The EPA is also proposing minor changes to the MSW Landfills NSPS and Emission Guidelines and Compliance Times for MSW Landfills. Specifically, the EPA is proposing to add provisions to the most recent MSW Landfills NSPS and Emission Guidelines (EG) that would allow affected sources to demonstrate compliance with landfill gas control, operating, monitoring, recordkeeping, and reporting requirements of the most recent NSPS and EG by following the corresponding requirements in the MSW Landfills NESHAP.

Reference: 40 CFR Parts 60 and 63 [EPA–HQ–OAR–2002–0047; FRL–9996–22– OAR] RIN 2060–AU18 National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills Residual Risk and Technology Review AGENCY: Environmental Protection Agency (EPA). ACTION: Proposed rule.

SCS Engineers, in collaboration with industry associations and environmental management group leaders, will be reviewing and commenting to EPA. Updates will be posted on our website blog and on SCS LinkedIn, Facebook, Twitter channels along with the public docket online at www.regulations.gov.

 

 

 

 

 

Posted by Diane Samuels at 6:03 am
Tag Archives: NSPS

Improving Global Air Quality – Perspective in the A&WMA Publication for Young Professionals

April 5, 2018

This article discusses global air quality and how the collaboration between policy-makers and the scientific community can have a continued positive impact on air quality in the U.S. This collaboration has been the primary cause for the improvements observed in air quality over the past few decades.

U.S. Environmental Protection Agency (EPA) programs, such as the New Source Performance Standards (NSPS), New Source Review, and Maximum Achievable Control Technology standards, have all had a significant impact on improving air quality by lowering the ambient concentrations of NOX, VOC, CO, SOX, and PM.

Some areas, such as southern California, have committed to working toward electrifying the transportation network, implementing more stringent standards on diesel fuel sulfur content, and encouraging heavier utilization of public transportation.

Read the full article here.

Author: SCS Engineers’ Ryan Christman, M.S., is an air quality engineer and environmental management  information systems specialist with experience in the oil and gas industry and the solid waste industry.  He is just one of SCS’s outstanding Young Professionals.

Posted by Diane Samuels at 8:57 am
Tag Archives: NSPS

NSPS/EG Rule Update – March 2018

March 6, 2018

SCS Engineers periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them.  Our most recent SCS Bulletin summarizes the new rules which took effect on October 28, 2016, with compliance obligations under the NSPS Subpart XXX rule beginning November 28, 2016. Originally, states and local air jurisdictions were to submit their proposed EG rules by May 30, 2017; however, there have been some delays in this process, which we condense and detail in this Bulletin. SCS will continually update coverage of this Rule on our website.

 

 

 

 

 

Posted by Diane Samuels at 9:24 am
Tag Archives: NSPS

SCS Advice from the Field: Landfills and Air Emissions

March 7, 2017

The clock is ticking even though some issues remain unresolved. Landfill owners should maintain close contact with their state/local regulatory authority regarding the status of the regulator’s state implementation plan, due by November 2017. 

 

Read and share the full article by David Greene, PE, here. 

EPA recently established expansive new air rules affecting MSW Landfills. Implementation of the new rules places new responsibilities on both the regulated community and regulators alike. However, some of these responsibilities are unclear and have created unresolved issues that should be addressed in close consultation now with your state/local regulatory authority.


For example, if a landfill is “new,” the facility is now subject to NSPS Subpart XXX, which is fully effective. A design capacity and NMOC emissions rate report should already have been submitted.


If NMOC emissions from a facility exceed 34 Mg/yr, then the landfill will need to submit a GCCS design plan within 12 months of the date of exceedance and install and operate within 30 months (no later than May 2019 for those triggering with the promulgation of the rule). If a landfill is an “existing emissions source,” it will be subject to the new EG rule (Subpart Cf).


Landfill owners should maintain close contact with their state/local regulatory authority regarding the status of the regulator’s state implementation plan, due by November 2017. That state implementation plan will prescribe the required compliance dates for an existing landfill, likely to be no later than the 2018/2020 time period. In either case, owners should become familiar with the rule and stayed tuned as compliance guidance evolves to address the unresolved issues.

 

Contact SCS Engineers to discuss the regulatory status in your state at Service@scsengineers.com, or call your local representative.

 

 

 

Posted by Diane Samuels at 3:00 am
Tag Archives: NSPS

Is Your Landfill, Landfill Gas, or Solid Waste Operation Ready For 2017? SCS’s free guidance helps you plan to meet and finance for NSPS rules

October 24, 2016

Getting a firm handle on a solid waste  operation and expenses is a challenge for any solid waste agency manager or landfill operator. It is particularly imperative in this era of “lean and mean” budgets and looming regulatory policy. Doing more with less is the watchword for most operations across the country still reeling from the financial impacts of the Great Recession.

SCS Engineers has created a package of articles to help you identify if your landfill, landfill gas, or solid waste operation is ready for 2017. We hope this useful guidance will help you plan for the upcoming year. SCS professionals are always available to answer questions and provide advice. Find the office or SCS professional nearest to you by clicking on one the links here: Offices and Professionals.

Download, print or share this package by using the download button under the articles or by using the navigation at left. The package includes the following information written by SCS National Experts:

  • New Rules for Landfills
  • How the Latest NSPS Rules will Affect Small to Mid-Size Landfills
  • Current Leading Issues in Solid Waste Financial Planning
  • The Value of a Solid Waste Rate Analysis

Download (PDF, 4MB)

 

 

Posted by Diane Samuels at 3:00 am
Tag Archives: NSPS

SCS clients are preparing for NSPS and NMOC with resources, information and timelines – you can too

October 11, 2016

SCS is working to get our landfill clients through NMOC and NSPS with timelines – they are prepared for what they need to do now and in the future. Listed here are the most popular and timely resources and information useful for your own planning.

Article in Waste360: explains who’s impacted and how to begin managing the costs.

SCS Technical Bulletin: a digest of hundreds of EPA regulatory policy into the information and timelines to act on now.

Article: strategic financial planning to support infrastructure costs.

Call our compliance specialists – find the office nearest you or email us at service@scsengineers.com 

 

 

 

 

Posted by Diane Samuels at 11:27 am
Tag Archives: NSPS

EPA Regulatory Alert: SCS Technical Bulletin – NSPS – EG Final Rule Published – August 2016

August 30, 2016

The EPA published NSPS – EG final rule in the federal register on August 29, 2016. This SCS Technical Bulletin compiles the 856 pages of NSPS and EG documents into 3 pages of the significant information you need to know. The rule takes effect 60 days after August 29, some requirements are linked to the publication date in the register.

 

Read the NSPS – EG Technical Bulletin

 

 

 

Posted by Diane Samuels at 10:04 am
Tag Archives: NSPS

SCS Alert: Prepare to take action soon after the Final NSPS/EG Rules for Landfills are published in the Federal Register.

August 1, 2016

Do you have NSPS or EG sites per the new definitions of “new” and “existing”?

Does your EG site have any upcoming planned or permitted expansions, or will it be commencing construction on an expansion permitted after July 17, 2014?

Will you need to submit/resubmit Design Capacity and NMOC reports to establish your sites status as subject to the new NSPS? Over, or under 34 Mg/year of NMOCs?

Are you a candidate for Tier 4? In the closed landfill subcategory?

For EG sites contact the SCS state representative by sending a request to service@scsengineers.com

SCS Engineers will be publishing Pat Sullivan’s Technical Bulletin Summary of Final NSPS/EG Rules for Landfills as soon as it is published in the federal register. Meanwhile, please contact your SCS Project Manager or service@scsengineers.com for answers to your questions or advice.  Follow SCS Engineers on your favorite social media site or check our events for new presentations, publications, and webinars explaining the rules in more detail.

 

Posted by Diane Samuels at 6:00 am
Tag Archives: NSPS

SCS Advice from the Field: Proven Methods to Reduce Contamination in Recycling

July 6, 2016

Contamination causes major problems for recycling programs. Improving communication plays a pivotal role in solving the issue.

 

Tracie Onstad Bills, Northern California Director, Sustainable Materials Management at SCS Engineers

Thank you for the responses and questions about my blog Minimizing Contamination in Recycling. It seems appropriate to provide answers to the most frequently asked questions and send more advice. Any program should be tailored to your current collection system; what works and what doesn’t work for your locality; the demographics of your community; and how your community views recycling.

In light of those considerations, here are some recommendations for ways to minimize contamination in recyclables:

  • Mail outreach materials to business and residents on a regular basis. When your community is adding recycling or switching to a new recycling program, mail outreach starting 6 months before the new services begin to inform and prepare the community for the change. Then every other month send new information about the program so people get used to hearing about the upcoming program, what is expected of them, and the positive difference they are making in their community.
  • Use social media to get your message out, Including NextDoor, Facebook, Twitter, the local government/community website, newspapers, community TV stations, and radio. One of the people who responded to my previous blog, Cyril May, even uses magic as a part of his environmental outreach. He is the recycling coordinator for the City of Waterbury, CT, and uses magic to demonstrate the power of recycling when he goes door-to-door or speaks at schools. “Turning a ripped up newspaper into a new newspaper shows the magic of recycling that everyone has,” he says. “Causing dollar bills to vanish in smoke and flame showcases the taxpayer dollars lost when we send valuable recyclables to incinerators.”
  • After the service starts, follow up with additional outreach. Highlight what people should do as well as what they should not do. Yes – I am a firm believer in excellent outreach, education, and communication!
  • Some studies have suggested providing trash cans that are the same size as the recycling can, because when the recycling is free, people often will throw their trash into the recycling containers in order to keep a small trash container for a cheaper cost. I am not an advocate of this method, however, I am a realist and know that this is one cause of contamination, so keep an eye on it!
  • Make sure your hauler keeps track of any contamination issues and the causes. Knowing what the contamination is and why it is caused, will help you determine the next steps on how to address it. For example, if you have slight contamination because residents and businesses are throwing in items that they think are recyclable, you can continue to educate them about what can and cannot be recycled. However, if they are putting trash in the recycling containers in order to save costs, that is another matter that needs to be addressed appropriately, and may include citations or fines.
  • Many people throw more than they should into their recycling containers because they think “the hauler will sort it at the facility,” and so they don’t feel the need to be extra cautious about how they sort. As part of your outreach, I would recommend letting the community know that the cleaner the materials, the better the market and the more economical the service. They need to understand that there are consequences when they are not careful about how they recycle.
  • Make sure that the materials you accept in your recycling program can, in fact, be recycled. Cities often accept items in recycling containers because they can be recycled in theory (for example, milk cartons and polystyrene), when, in fact, they may not be. Depending on the local dynamics, recycling markets, recoverability at the recycling facility, or other barriers, certain materials may or may not be recycled. Be consistent with the materials you accept and don’t take items that may cause confusion.
  • In California, we have very diverse demographics and multiple languages. Providing outreach in those different languages, and even better, with pictures, will help your community fully understand the recycling program.
  • Go into the schools to get the kids engaged and excited about recycling. If you are starting a new recycling program, facilitate an assembly right before and/or after the service starts. Kids often influence their family’s behavior in such matters.
  • Multi-family dwellings should be treated differently than single-family residences. Because residents of multi-family dwellings do not typically pay for the service directly, their containers will almost always be contaminated because there is no ownership of the responsibility. There are other barriers as well, such as illegal dumping, fluctuation of tenants, move-in or move-out purging of material, etc. I have a different set of recommendations for multi-family dwellings which I consider one of the toughest nuts to crack.
  • Make sure the recycling haulers place non-collection tags on containers that are contaminated. After a few violation notices and the threat to suspend service, residents and businesses usually improve, especially when they realize that someone is watching them.
  • Be diligent when transitioning to your new recycling program and closely monitor how your residents and businesses are doing. I would recommend having a few interns go out for the first month or two and conduct random lid flips. Leave notes that say “good job – you’re an excellent recycler” to reinforce the good behavior. This will also provide a pulse on how the program is doing, where the problems are, and if there are certain districts of the city that are more contaminated than others. By isolating the areas that have high contamination, you can focus your outreach and education to the regions that need message reinforcement.
  • Be flexible. Remember that your program will be evolving, so go with the flow, and be sure to celebrate your successes!

Learn more about recycling programs by reading Success In Selective Routing – Resource Recycling or the SCS project and case studies below:

 

As always, feel free to send me your questions and comments. Contact Tracie here.

 

 

Posted by Diane Samuels at 6:00 am
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