American Oil and Gas Reporter - December 2016 - 79

SpecialReport: Insurance And HS&E Update
trifugal compressors, and storage vessels
built, modified or reconstructed after Aug.
23, 2011.
"The rule was proposed on Aug. 23,
2011, and finalized on Aug. 16, 2012,"
Reeves says. "In the regulatory world,
proposing a new rule, getting public comments, responding to those comments,
and finalizing the rule in less than a year
is fast. We have rules applying to boilers
that went back and forth for a decade before they were finalized."
Under president-elect Trump's administration, Reeves predicts the pace of new
regulations will slow. "However, I have
to caution that in many ways, EPA has
been proposing regulations in response
to litigation from nongovernment organizations such as the Sierra Club. With the
shift in administration, it is unlikely environmental groups will dial back their litigation if they perceive inaction from EPA."
At the urging of environmentalists,
EPA in November issued an information
collection request (ICR) asking oil and
gas companies to detail the type of equipment at onshore production facilities,

Reeves notes. She says EPA's stated goal
is to determine whether it should develop
performance standards limiting emissions
from existing equipment that does not fall
under New Source Performance Standards
such as Quad O and the Quad Oa rules.
"The ICR has been finalized, and EPA
sent the request letters to operators on
Nov. 10," Reeves notes. "Responding is
mandatory for those who receive the request. While EPA may choose not to develop regulations based on the information
it receives, or do so more slowly, operators
still will need to provide a response."
A select group of companies will need
to not only enumerate their equipment,
but also conduct follow-up site-specific
surveys, Reeves warns. "These surveys
will require someone going to the site to
gather details on the efficiency of emission
control devices, including downtime,"
she says. "They also will require sitespecific analyses."
Leak Detection And Repair
Regardless of the ICR's ultimate impact, Reeves says operators will continue

to grapple with NSPS OOOOa, an expansion of Quad O that is designed to reduce both methane and volatile organic
compound emissions.
"This rule's biggest change is requiring
operators to perform leak detection and
repair (LDAR) surveys for new, modified
and reconstructed well sites and compressor stations," Reeves says. "Many
well pads constructed or modified after
Sept. 18, 2015, will be required to perform
semiannual surveys. Compressor stations
built or modified after that date must
perform quarterly surveys."
Reeves encourages operators to create
and test leak detection and repair plans
as soon as possible. "Operators have until
June 3, 2017, to develop LDAR plans,
buy equipment or hire contractors, set up
the necessary record keeping, and conduct
the first surveys at affected sites," she
says. "However, if they wait until the last
minute, people and equipment will be
more expensive."
Even companies that outsource surveying
should develop internal expertise, Reeves
advises. "Many firms have popped up in

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American Oil and Gas Reporter - December 2016

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