oil and gas

June 24, 2024

Join SCS Engineers at the 2024 PWS Permian Basin Summit. The Produced Water Society brings together industry-leading speakers such as Neil Nowak to address the produced water issues faced by operators, water midstream companies, and water service providers. Neil will present “Produced Water Recycling and Evaporation Facilities” as a Roundtable Presentation at the event.

Produced water experts with Permian Basin experience will discuss the existing solutions, technological innovations, and produced water management best practices needed to keep the most productive unconventional shale play in the world pumping hydrocarbons while ensuring sustainable business operations and safeguarding the local environment and freshwater resources.

Join SCS Engineers to solve environmental challenges.

Carbon Sequestration & Deep Well Injection
Greenhouse Gas Services
Oil and Gas Services

Register today!

Posted by Brianna Morgan at 10:03 am

June 24, 2024

Meet with SCS Engineers at the 2024 Railroad Commission (RRC) of Texas Regulatory Conference July 30-31 at the AT&T Hotel and Conference Center to inform the oil and gas sector on the applicable laws, rules, and procedures for hydrocarbon production in Texas.

Join SCS Engineers to solve future energy challenges like:

Register today!

Posted by Brianna Morgan at 9:57 am

April 5, 2024

The Pennsylvania Independent Oil & Gas Association (PIOGA) is hosting its 2024 Spring Meeting at Rivers Casino in Pittsburg, Pennsylvania. This year’s event theme, “Climate, Commodities, and Chaos: Threats to a Strong U.S. Energy Game Plan,” will explore topics concerning changes in the oil and gas industry, including regulatory updates, consumer preferences, and market sentiment. The agenda features an oil and gas producers’ roundtable on navigating risks in energy development, regulatory updates, and a post-meeting cocktail reception where attendees and exhibitors can network with each other.

Registration is open to PIOGA members and non-members, with special pricing for students. Register today!


Posted by Brianna Morgan at 9:39 am

October 13, 2021

containment ponds
An effective and safe solution is the evaporation or storage of the water in lined containment ponds after separation and removal of the hydrocarbon component from the water.


In an environmentally safe, less costly, and efficient manner, the disposal and recycling of millions of gallons of production water (brine water) and flowback water generated from the oil and gas industry annually continue to be challenging. While new technologies are on the horizon, there remains a long road ahead to their implementation.

In his article in Geosynthetic News, Neil Nowak writes in detail about three sites in Wyoming, Utah, and Texas that are evaporating or recycling water in geomembrane-lined ponds. Nowak’s article demonstrates the successful use of black high-density polyethylene (HDPE) liners to increase evaporation over clay or unlined ponds and using a white liner to reduce evaporation relative to a black liner.

Each project has been operational for several years; they continue to expand under their permits. Nowak takes us through a combination of favorable factors to the evaporative process, including the natural characteristics of each sites’ climate and the business and environmental goals.

The projects are interesting in that each facility provides oil and gas production companies in the area with a large commercial alternative to production water and flowback disposal versus numerous small ponds or disposal via injection wells.


Energy industries using HDPE liners for flowback water evaporation/recycling ponds



About the Author: Neil Nowakover 30 years of experience in the consulting engineering industry, including civil, solid waste, produced water impoundments, stormwater engineering, and construction projects.

Mr. Nowak has managed environmental compliance, evaporation pond design and permitting, and construction quality assurance activities across the Southwest. As a land-use planner and Environmental Engineer, he explains how various environmental technologies work under specific conditions to companies and the public. Often he is called to public comment meetings and county commissioner meetings, where he prepares and presents project details for review and approval. He works closely with local, state, and federal regulatory agencies to ensure that the engineering and construction of sites comply with all current applicable requirements.





Posted by Diane Samuels at 6:00 am

June 24, 2016

SCS Engineers has published two Technical Bulletins summarizing the O&G NSPS final rule and outlining the new LDAR requirements. The two Bulletins explain the modification of how oil and gas sources will be permitted under the Clean Air Act and the new requirements to reduce methane leaks from new oil and gas facilities consistent with the EPA’s New Source Performance Standards.

Reference the U.S. Environmental Protection Agency (EPA) new source performance standards for Crude Oil and Natural Gas Production, Transmission and Distribution (O&G NSPS), which includes amendments to 40 CFR Part 60, Subpart OOOO and a new Subpart OOOOa. Subpart OOOOa will apply to facilities constructed, modified or reconstructed after September 18, 2015.

Click to read or share the Technical Bulletins:

Summary of Final Oil and Gas NSPS Rule

LDAR Requirements in the Final Oil and Gas NSPS Rule


For copy of the rule and related documents:



For more information contact:

Pat Sullivan, REPA, CPP, BCES

(916) 361-1297

Lucas Marsalek

(805) 346-6591

(800) 767-4727



Posted by Diane Samuels at 10:13 am

May 13, 2016

An SCS Engineers Technical Bulletin will be released early in the week.

The U.S. Environmental Protection Agency issued limits on methane emissions from oil and gas wells that are more stringent than those it proposed last year. The final regulations released on Thursday, May 12, 2016, will add hundreds of millions in additional costs per year; at least 25 percent higher than the preliminary version published in August 2015.

EPA Administrator Gina McCarthy told reporters on a conference call that the mandates, applying immediately to new and modified wells, are a “critical first step in tackling methane emissions from existing oil and gas sources.”

Under the rule, companies must upgrade pumps and compressors while expanding the use of “green completion” technology meant to capture the surge of gas that can spring out of newly fracked wells. Such green completion techniques have been required for new and modified natural gas wells since 2015, but Thursday’s rule would broaden the requirement to oil wells too.

Take me to the EPA summaries. Click on the information sheets listed below:

Posted by Diane Samuels at 6:13 pm

March 7, 2016


Fugitive emissions come in all shapes and sizes, are found in several industry types, and the constituents entrained in them generally have potential negative impacts on our health and the environment.  That being said, no wonder they are called “fugitive” emissions.  It seems to be in our human nature to seek out, capture, and prevent any sort of fugitive activity.


LDAR and other environmental and compliance services are available from SCS Engineers.
LDAR and other environmental and compliance services are available from SCS Engineers.

Long story short, an escapee from San Quentin and any uncontrolled methane air molecule may be more similar than we may presume.  In fact, a common LDAR practice is to use an infrared imaging camera; similar to the camera often used in search of fugitive criminals.

On a serious note, fugitive emissions are something that both industry and regulators have been focused on for decades, and the past and present efforts made to limit them are no less than remarkable.

Specific to Onshore Oil and Gas Exploration & Production, the Federal Regulations applicable to fugitive emissions are fairly young.  Finalized in 2012, NSPS OOOO is no longer a toddler and is in the middle of growing into NSPS OOOOa (Public Comment Deadline March 11, 2016).  On a national scale, NSPS OOOOa will expand fugitive emission monitoring and control requirements (VOC’s and methane) to several facility types associated with the industry and is expected to be finalized before the close of 2016.

In California, fugitive emissions from Onshore Oil and Gas Exploration & Production have been regulated for a long time.  In fact, the O&G industry in Santa Barbara County has dealt with fugitive emission requirements since 1979.  Since then SCS Engineers has been assisting with fugitive emission monitoring for our valued clients.  Today, SCS Engineers provides the Oil and Gas Exploration and Production industry with efficient and effective LDAR services.

So fear not, SCS Engineers is ready to supply the knowledge and skill set you need to stay compliant, maintain your operations, and respect your bottom line.  Remember, unless the doors are closed, pumps are turned off, and equipment is flushed and plugged; fugitive emissions requirements and LDAR will likely still apply. 

If you are considering a new LDAR program, restoring an existing program, or are still trying to figure out what LDAR actually is, below are a few basic pieces of advice:

Applicability:  Determining Federal vs. State oversight is the first step.  Non-Major Source Oil and Gas Production facilities are either subject to NSPS OOOO (soon to be OOOOa) or a related State specific rule (i.e. Colorado Regulation 7).  Once oversight is determined, then there may still be exemptions for your facility (i.e. facility constructed before August 23, 2011).  And finally, once regulatory oversight is confirmed and you determine that LDAR is required for your facility, then the last step is to figure out which equipment is applicable (i.e. VOC content > 10% by weight).  Basically, an applicability determination can be daunting.

Equipment: EPA’s Method 21 is historically and currently referenced in all LDAR regulations.  Method 21 requires an instrument such as the Flame Ionization Detector (FID) or Photo Ionization Detector (PID).  More recently the Optical Gas Imaging (OGI) Camera has been included in LDAR regulations and utilized in LDAR programs.  Presently, there are several instrument technologies that exist and are in the works, but not yet mainstream in Oil and Gas sector.  Ultimately, if you were to find yourself conducting LDAR monitoring at your oil and gas facility tomorrow per an established regulation, you would most likely need to use an FID or OGI.

Recordkeeping:   Personally, I like the simplicity of using paper forms for field notes; however, the old-fashioned way comes with risk. The up-front and ongoing data involved with an LDAR program is too much for maintaining a paper to computer process, regardless of how organized you think you are. Therefore, a computer database platform is recommended and necessary for managing your LDAR recordkeeping. Beyond just recordkeeping, a database platform can organize schedules, alerts, generate reports, extract trends, and many other applications to help keep your LDAR program compliant.  One such platform worth considering is SCSeTools™.  This cloud-based software can provide the database capabilities used on the desktop, but almost more importantly, provides mobile data input capabilities with the SCS MobileTools™ application fit for Android and IOS systems. Keep the fugitives from escaping, and document containment for the authorities!

If you are not already implementing an LDAR program at your Oil and Gas Production Facility, it may be on the near horizon; especially after Leo’s recent Academy Award speech.


Marsalek_LucasAbout Lucas Marsalek: Lucas has been an Environmental Consultant for over 8 years; he applies his expertise as a leader for oil and gas production environmental and regulatory compliance projects. Marsalek has a B.S. in Forestry and Natural Resource Management from California Polytechnic State University, San Luis Obispo, CA.

Whether you want to discuss LDAR or Dodger baseball, don’t hesitate to contact me, or SCS Engineers.



Learn more on the SCS service pages and read SCS project case studies from across the nation to help fine tune your program.



Outside links to the EPA proposed rulemaking website:


Posted by Diane Samuels at 6:00 am

November 10, 2015

Technical bulletins provide salient information in a condensed format. These summaries are useful to understand and start to plan for potential impacts to your business. Both bulletins posted today include deadlines and additional resources with contact information to help answer your questions. The two bulletins posted today are as follows:

  • Summary of the Clean Power Plan includes the final standards for new and existing Electric Utility Generating Units (EGUs). The Technical Bulletin reviews the U.S. EPA determination that  the best system of emission reduction (BSER) consists of three building blocks; how the EPA determines the degree of emission limitation achievable through the application of the BSER for each type of unit; and how quickly and to what extent the measures encompassed by the building blocks could be used to reduce emissions. States will be required to submit a final plan, or an initial submittal with an extension request, by September 6, 2016. The types of plans and cost-effective strategies suggested for states to tailor their plans to meet their respective energy, environmental, and economic needs and goals, and those of their local communities is in the final sections.
  • Summary of Proposed Oil and Gas NSPS U.S. EPA promulgated an amended Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (NSPS). Specifically, EPA proposed amendments to 40 Code of Federal Regulations (CFR) Part 60, Subpart OOOO and proposed an entirely new Subpart OOOOa. EPA also promulgated a draft control technique guidelines (CTGs) document for the oil and natural gas industry. The CTG is intended to provide state, local and tribal air agencies with information to assist them in determining reasonably available control technology (RACT) for reducing volatile organic compounds (VOC) emissions from select oil and natural gas industry emission sources in ozone nonattainment areas. Comments on the proposal are due November 17, 2015, and the final rules are slated to be promulgated in June 2016. Rule details are provided in the Technical Bulletin and table within the Technical Bulletin.

Clicking the title of each Technical Bulletin will take you to the full text. Each Bulletin may be shared, emailed, or printed.


About Pat Sullivan:

Pat Sullivan, Sr. VP, SCS Engineers
Pat Sullivan, Sr. VP, SCS Engineers

Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.

Click on Pat’s name to see his full qualifications and experience.


Posted by Diane Samuels at 6:31 pm

November 2, 2015

Transparency initiatives established by EPA as part of its Next Generation Compliance initiative mean increased reporting and recordkeeping for refineries.
Transparency initiatives established by EPA as part of its Next Generation Compliance initiative mean increased reporting and recordkeeping for refineries.

The U.S. Environmental Protection Agency (EPA) issued a final rule on September 29, 2015, seeking to further control emissions of hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) from petroleum refineries.

This action finalizes the residual risk and technology review conducted for the petroleum refinery source category regulated under the National Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR Part 63, Subpart UUU), including the refinery Maximum Achievable Control Technology Standard (MACT) 1 and Refinery MACT 2.

Click here to read the Technical Bulletin 

Posted by Diane Samuels at 2:10 pm