On October 17, 2016, the Environmental Protection Agency celebrated the 30th anniversary of the launch of the Toxics Release Inventory (TRI).
It was a timely reminder: while TRI and associated EPCRA reporting isn’t due until July, the new year is around the corner, and that means the reporting season is coming up fast. First up? March 31. The deadline for Air Emissions Inventory reporting, Mass Emissions Cap & Trade (MECT) annual reconciliations, and Greenhouse Gas Inventory reporting all fall to the same day—with the last being particularly complex, due to recent rule changes.
We know you didn’t go into business to be burdened with environmental bureaucracy. In contrast, the principals and professionals here at EDGE bring decades of experience to emissions inventories and reporting.
We work closely with clients in manufacturing, upstream oil & gas, refining, petrochemicals, natural gas processing, and other industries to assess their emissions profiles, complete the necessary reporting, and ensure that it is filed in a timely manner.
EDGE lets you focus on your core business with the confidence of knowing that you remain in full compliance with mandatory environmental reporting requirements: local, state, and federal. Whether you’re not yet a client, or one of the many who rely on us every year, EDGE is on your side.
TIPS ON HOW TO PREPARE FOR REPORTING SEASON
• Check for changes in reporting applicability for your site
• Collect your operating data from 2016
• Gather data on spills and other releases that occurred in 2016
Stay ahead of the deadlines: let EDGE bring further insight to your annual emissions reporting.
Last March, the EPA announced its next step in reducing emissions from the oil and natural gas industry: moving to regulate emissions from existing sources. In May, the EPA issued a draft Information Collection Request (ICR) to require oil and natural gas companies to provide extensive information needed to develop regulations to reduce methane emissions from existing oil and gas sources. Afterwards, the agency issued a Request for Information to seek commentary on innovative strategies that can accurately and cost-effectively locate, measure and mitigate methane emissions. The comment period on the ICR closed on August 2, 2016. EPA has stated that they expect to issue the ICR this fall.
With extensive experience serving the energy and oil and gas industries across the U.S., EDGE can help effectively manage company response programs. We have experience leading companies through Utility Maximum Achievable Control Technology (MACT) and Refinery MACT ICRs and subsequent rulemaking. We’ve assisted clients with their initial applicability reviews and reporting for the New Source Performance Standard (NSPS) Subpart OOOO and Greenhouse Gas Reporting Subparts C and W. Additionally, we have other oil and gas experience that required direct measurement of VOC emissions from oil and condensate storage tanks in the Dallas-Fort Worth area, as well as evaluation of VOC and hazardous air pollutant (HAP) emissions from produced water/saltwater storage tanks servicing oil and gas wells. These projects, which were managed by now EDGE personnel, give EDGE a unique insight into the operations of oil and gas facilities—insight that will prove beneficial in helping operating companies respond to the forthcoming ICR.
It is not too early to begin preparations for the ICR. If you plan on using a consultant to support this resource-intensive effort, then engage one now to facilitate preparations. Give us a call. We would love to buy you lunch and discuss a solution that makes sense for you.
Take the next step by contacting Chris Colville and George Holder for assistance in tackling this environmental challenge hurdle, and we look forward to providing further insight.
EPA’s Actions to Reduce Methane Emissions
Proposed Information Collection Request
Upstream Oil and Gas Storage Tank Emission Measurements
Emission Factor Determination for Produced Water Storage Tanks
With information about EDGE’s full range of services necessary to support project development from concept, through construction and into operation, our new Knowledge Center provides our clients further insight. Check it out.
The Federal Energy Regulatory Commission (FERC) and the U.S. Army Corps of Engineers (USACE) have signed a Memorandum of Understanding (MOU) to enable hydropower development at the USACE’s federal facilities, to synchronize each agency’s permitting process.
The MOU, which is an update to the previous MOU signed by the agencies in 2011, offers a more streamlined approach for project developers in an effort to improve efficiency within the FERC and USACE processes and to reduce permitting times, providing a single document and ensuring more certainty and less risk.
“The potential for hydropower development in this country is significant, particularly at existing Corps facilities,” said FERC Chairman Norman Bay. “Today’s MOU is a positive step toward the development of these resources. Thank you to the Corps for their commitment to working with us to streamline our processes.”
“This strengthened collaboration between FERC and the Army Corps of Engineers advances the Obama
Administration’s work to transition to a clean energy economy, and reduce carbon pollution,” said Jo-Ellen Darcy, Assistant Secretary of the Army for Civil Works. “This synchronized approach will shorten the time it takes the private sector to develop and construct new hydropower, and will help us more efficiently use our existing infrastructure. It is also advancing our efforts to find alternative ways to finance new infrastructure.”
The synchronized approach has two phases – an environmental review phase followed by an in-depth technical, engineering and safety review phase. During Phase 1, the developer, FERC staff and Corps staff will meet early to discuss the developer’s proposal and the information needed to support the agencies’ permitting decisions. The environmental effects of the proposed project will be evaluated up front through a single, joint environmental document and a FERC license will be issued.
Phase 2 will include the developer coordinating with FERC and Corps staff to prepare a final project design and submitting that design to the Commission and the Corps. Once all of the Corps’ preconstruction requirements have been completed and the Commission receives the Corps’ written construction approval, the Commission will authorize the construction phase of the project.
Currently, the FERC issues preliminary permits and licenses to non-federal entities for the development of hydropower projects, including projects utilizing federal dams or other federal facilities, while the Corps operates water resources projects throughout the nation where potential exists for the development of hydropower and allows the development of hydropower at suitable projects. The updated MOU will simplify the permitting processes, leaving less room for error and provide an expedited timeline for the construction projects to get underway.
FERC News Release
Building a positive company culture leads to successful business performance, and a positive outlook on the job overall. At EDGE, we attempt to foster that growth through our core values. We are striving to build an internal company culture that reflects these values, to define every aspect of the business we conduct, and to continue growing towards our goal of becoming the leader in environmental consulting services. Our Mission at EDGE is to deliver responsive service and meaningful solutions to avoid, reduce and eliminate our clients’ environmental challenges.
Our Core Values Are:
We strive to become one of the most sought-after providers of environmental engineering and scientific consulting services.
We endeavor to meet or exceed the expectations of our clients in all aspects of their environmental compliance program.
We promote a collegial atmosphere in which all individuals are encouraged to learn, improve and excel and to become leaders in the consulting, business and civic communities.
We encourage diversity among our members and respect for differences among us.
We work continuously to enhance the supportive attitude, common bond and collective sense of humor ― the special working atmosphere ― which is a hallmark of our firm.
We pursue our belief that individuals with a sense of family and community and with interests outside the company are better for it.
Embracing these values will lead us closer to our common goal, of being the best in our field for our clients.
This year’s Texas Environmental Superconference offers an exciting opportunity to hear leading experts discuss case law updates and the most significant environmental issues impacting our industry. EDGE looks forward to meeting and collaborating with our peers to shed light on the implications and challenges associated with new regulatory policies and discussing solutions to successfully deliver projects.
We hope to see you in Austin and look forward to providing further insight.
28th Annual Texas Environmental Superconference
Austin, Texas | August 4-5
Based on their review of recent monitoring data, the EPA has concluded that facilities are releasing more air toxics than they are reporting. The EPA believes that the emission excess is primarily due to faulty or leaky equipment, or improper operation of the machinery.
Since 2004, the EPA has worked to address the issue of excess toxic air. The EPA plans to continue this initiative in the years 2017-19, by expanding it to include air emissions from large product storage tanks and hazardous waste generators and treatment, and storage and disposal facilities. The EPA’s effort will include leak detection and repair requirements for product storage tanks and hazardous waste tanks, surface impoundments or containers, as well as related waste treatment equipment.
As an industry partner, EDGE provides impactful solutions to successfully navigate EPA’s regulations. Let us work with you to put a plan in place to make the process streamlined and seamless, such as evaluating how regulatory changes will impact existing or new projects, analyze how existing or future projects can be designed and operated to avoid being subject to a new rule or program, as well as provide assistance with preparing any documentation that is required by a new rule or program. EDGE also provides ongoing support during the implementation of new procedures and practices, to comply with the new requirements and can negotiate with federal and state agencies to minimize the compliance burden.
Cutting Hazardous Air Pollutants
Enforcing Law: [link to: https://www.epa.gov/enforcement/enforcement-basic-information]
Climate, Air Quality, and Permitting Proposals for the Oil and Natural Gas Industry [link to: https://www3.epa.gov/airquality/oilandgas/pdfs/20150910presentation.pdf]
Christopher J. Colville of Edge Engineering and Science was featured on the Schirrmeister Diaz-Arrastia Brem LLP Law Firm website, advising oil and gas industry clients affected by the new modifications to the EPA methane emission reduction rules. Read the full article.
The Environmental Protection Agency (EPA) and the White House are suggesting drastic changes to regulations that could change the way businesses function moving forward.
Hazardous waste shipments will no longer be tracked using printed long-forms, and instead will be tracked electronically (referred to as E-Manifests). This will allow regulators to make sure that hazardous waste shipments are being tracked appropriately, and it will also shed light on current businesses that are not tracking shipments as completely as they should be. This will eliminate long paper forms from over 150,000 sites. The rule was published February 2014, and will take effect in 2018.
The EPA is also planning to adjust air regulations, instituting a new national ozone standard of 70 parts per billion. After reviewing photochemical oxidants and national ambient air quality standards (NAAQS), it was noted that this change is necessary to protect public health and welfare. This change will affect both small and big businesses alike, and will make it tougher to have permits approved. Not only that, but the EPA is also looking to cut down on air toxics emissions across landfills, aluminum plants, brick and clay ceramics, and cement manufacturers.
Additionally, for the first time in 40 years, chemical safety laws will change. The Toxic Substances Control Act (TSCA) will be reformed, which will allow the EPA to identify and restrict additional chemicals from being allowed at job sites. Meaning the 83,000 chemicals recorded on the TSCA list will increase, in an effort to create more safety and protection.
Finally, although the EPA signed the Clean Water Rule in June of last year, it has seen much opposition on the state level, with multiple states filing lawsuits against the EPA to prevent the changes from taking place. The Rule protects wetlands, prairie potholes, Delmarva bays, vernal pools and irrigation and supply ditches from contamination. Although the ruling was supposed to go into effect in August of 2015, it is currently stalled until a verdict is reached in federal court.
Other rules taking effect are water treatment plants monitoring for additional contaminants and National Pollutant Discharge Elimination System permit holders submitting their reports electronically, rather than in printed form.
Sources: Hazardous Waste Manifest System | Clean Air Act | TSCA Modernization
EDGE’s client, Enterprise, the second-largest transmission and Pipeline Company in Houston, had a goal to capitalize on the shale boom by being first-to-market with the world’s largest refrigerated ethane export facility. Enterprise knew they wanted a Gulf Coast location, and ultimately decided on the Houston Ship Channel.
Since Enterprise had a facility opening date scheduled for the third quarter of this year, the aggressive construction timetable made for an aggressive air-permitting schedule for EDGE. Consequently, a lot of uncertainty occurred during the permitting process, primarily due to the engineering design, which was happening simultaneously. Usually the permit application is based on a completed engineering design. However in this case, because the design was incomplete, EDGE played a significant role in both design and permitting processes, assisting Enterprise concurrently in multiple facets of the project.
The permit was issued on time and with the operational flexibility Enterprise wanted. Enterprise CEO Michael Creel stated, “This facility is another example of Enterprise serving incremental market demand for growing supplies of U.S. energy.” The facility will meet the growing demand for domestic energy, and will be able to refrigerate approximately 240,000 barrels of ethane per day. The project is showing promise, already getting major attention from potential international clientele. Not only that, but the facility will decrease U.S. reliance on international oil resources, as well as create domestic jobs. EDGE was pleased to deliver the expedient and confidential service that a project of that caliber required.
Source: Houston Business Journal