American Oil and Gas Reporter - December 2016 - 80

response to the rule. They are too new to
have strong track records and reputations,
so operators need to have internal resources
who know enough to find good vendors or
help manage vendors," she explains.
At a minimum, Reeves says operators
should make sure vendors understand
what needs to be monitored and what
does not. "If the vendor cannot distinguish
between a leak and a vent, that is a huge
red flag," she says.

"As they apply the rule, operators
should think about how they are going to
prove compliance," she adds. "In the refining and chemical industries, which
have been subject to LDAR rules for
some time, companies not only have to
find and repair leaks, but also document
that they looked at all other components
and found they were not leaking."
NSPS OOOOa does not require such
detail explicitly, but Reeves cautions that

neither do the comparable rules governing
the refining and chemical sectors. "Fortunately, EPA has said it does not intend
the LDAR component of OOOOa to mirror the LDAR requirements for other sectors, which would make it extremely expensive," she says. "As the rule evolves,
we are going to have to figure out where
the line is between documenting compliance and doing so much that operators
cannot cope."
❒

API: BOEM's Seismic PEIS Is Overkill
WASHINGTON-The American Petroleum Institute is expressing some misgivings after an initial look at the Bureau
of Ocean Energy Management's draft programmatic environmental impact statement
(PEIS) to protect the Gulf of Mexico's
marine mammals and coastal environments
from the potential impacts of geological
and geophysical surveys. The PEIS was a
condition of a federal court settlement
reached earlier this year between BOEM
and the Natural Resources Defense Council
and its co-plaintiffs, the bureau notes.
According to API Senior Policy Adviser
Andy Radford, the draft document follows

more than a decade in which BOEM and
the National Marine Fisheries Service
consulted with the oil and gas industry
to develop a regulatory framework to
guide seismic surveying in the Gulf. After
its first look at the PEIS, API has a
number of concerns, he says.
"We will be looking closely at the
various mitigation measures proposed for
each of the alternatives," Radford relates.
"Our initial read shows that the restrictive
nature of some of the proposed mitigations
would threaten the economic and operational feasibility of performing seismic
surveys in the Gulf of Mexico."

BOEM Director Abigail Ross Hopper
characterizes the measures as vigorous.
"BOEM's approach offers the strongest
practicable safeguards in an effort to
eliminate or reduce impacts to marine
mammals and the environment," she maintains. "We continue to conduct research
and monitor the science of this field, and
to work with other agencies and stakeholders to . . . protect these resources."
However, Radford points out, the industry has a decades-long history of performing seismic surveys safely with no
demonstrable harm to marine mammal
populations. He cites the bureau's own

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American Oil and Gas Reporter - December 2016

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