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New Compliance Guide from EPA for Small Oil and Gas Operations

A new Small Entity Compliance Guide has been released to help small oil and gas operations comply with the latest federal air quality emission standards. Published by the U.S. Environmental Protection Agency (EPA), this guide aims to simplify adherence to the 40 CFR Part 60, Subpart OOOOb regulations, which cover new, reconstructed, and modified sources within the oil and natural gas sector.

Overview

The guide, developed under the Small Business Regulatory Enforcement Fairness Act (SBREFA), addresses essential environmental and human health issues by setting standards to control greenhouse gas (GHG) and volatile organic compound (VOC) emissions from affected facilities. It provides a structured approach for small entities to navigate the complex regulatory landscape and ensure compliance with federal standards.

Key Features

  1. Applicability:
    • The guide outlines which entities and facilities are subject to the new standards, including specific criteria for well completions, liquids unloading, and associated gas management.
  2. Compliance Timetable:
    • A detailed timetable is provided to help small businesses understand the compliance deadlines for different types of facilities. For example, new or modified sources that commenced construction after December 6, 2022, must adhere to the regulations starting May 7, 2024.
  3. Super-Emitter Events:
    • It introduces the Super-Emitter Program, which mandates reporting and corrective actions for significant methane emissions events (100 kg/hr or more).
  4. Detailed Requirements:
    • Sections in the compliance guide cover specific environmental compliance requirements, such as testing, monitoring, reporting, and record-keeping for various types of equipment and operations.
  5. Support and Resources:
    • The compliance guide includes contact information for further assistance and references to additional resources and documents to help small entities stay compliant.

Compliance Support

Small oil and gas operators in Pennsylvania are encouraged to review the guide thoroughly and reach out for assistance in implementing these new standards. For more detailed information, the full compliance guide can be accessed or downloaded here.

EPA Proposes Ban on TCE: How it May Affect Small Businesses

In a significant move aimed at safeguarding public health and the environment, the U.S. Environmental Protection Agency (EPA) has proposed a ban on the use of trichloroethylene (TCE), a chemical solvent with known serious health risks, under the Toxic Substances Control Act (TSCA). While this proposal has wide-reaching implications, it particularly resonates with the small business community, given the various industries that use TCE in their operations.

Where TCE is Often Used:

Small businesses may use TCE in cleaning and degreasing (including spot cleaning, vapor degreasing, cold cleaning, and aerosol degreasing) substances, and if they manufacture refrigerants or use refrigerants. TCE is also used in paint and coat manufacturing, plastics material manufacturing, wood window and door manufacturing, pharmaceutical preparation, and printing machinery. Additionally, TCE is also found in consumer products such as typewriter correction fluids, paint removers, paint strippers, adhesives, spot removers, cleaning fluids for rugs, and metal cleaners.

The proposed ban on trichloroethylene (TCE), while primarily aimed at protecting public health and the environment, will have several potential effects on small businesses.

Transition to Safer Alternatives:

Small businesses that currently use TCE in their products or processes will need to transition to safer alternatives. While this transition may involve some initial costs, it is likely to lead to long-term benefits, as safer alternatives are generally associated with lower health and environmental risks. Small businesses should consider exploring these alternatives and assess their feasibility in their operations.

Compliance Costs:

Small businesses will need to ensure compliance with the proposed rule, which may require changes in their manufacturing processes, product formulations, or supply chains. These adjustments may come with associated costs, including investing in new equipment or materials, revising safety protocols, and retraining employees.

Worker Protections:

The proposed rule includes stringent worker protections for limited remaining commercial and industrial uses of TCE. Small businesses will need to invest in safety measures to protect their employees from potential TCE exposure. This may involve additional training, personal protective equipment, and equipment upgrades.

Phased Transition for Some Uses:

The proposal acknowledges that for certain limited uses of TCE, there will be a longer transition period. Thus, small businesses may have more time to adapt to alternative chemicals or processes. However, they will still need to comply with the worker protections outlined in the proposal.

Reduced Legal and Financial Risks:

By proactively adopting the ban and transitioning to safer alternatives, small businesses can reduce the risk of legal and financial liabilities associated with TCE exposure. This can protect them from potential lawsuits, fines, and reputational damage.

Environmental and Health Benefits:

The proposed ban aims to reduce the adverse health effects and environmental contamination caused by TCE. Small businesses located in areas with historical TCE contamination can benefit from a cleaner and healthier environment, potentially improving the quality of life for their employees and the surrounding community.

Awareness of Health Risks:

The proposed ban raises awareness about the health risks associated with TCE, which can benefit small businesses by encouraging them to prioritize the safety of their employees and customers. Implementing safer practices can enhance the reputation of a business and improve relationships with stakeholders and the local community.

Public Comments and Engagement:

Small businesses have the opportunity to provide feedback during the public comment period, enabling them to express concerns or suggest adjustments to the proposed rule. This engagement can help shape the final regulations and ensure that the unique challenges faced by small businesses are considered.

Topics of interest to small businesses, in which EPA is requesting comments on as noted in the federal register notice, are the following:

  • EPA requests public comment on reasonable compliance timeframes for small businesses, specifically on whether and how to provide longer compliance timeframes for transitioning to alternatives for uses requiring reformulation and cleaning processes for cleaning parts for national defense or cleaning medical devices.
  • EPA requests public comment on differing compliance or reporting requirements or timetables that account for the resources available to small entities.
  • EPA requests public comment on the feasibility of use of alternatives to TCE and their availability for conditions of use that drive the unreasonable risk.
  • EPA requests public comment on how the rulemaking should consider TCE alternatives in light of ongoing regulatory scrutiny.
For those small businesses interested in voicing their opinions on this proposal, the EPA will accept public comments on or before November 30, 2023.

1-BP Added to Hazardous Air Pollutants List

EPA has now added 1-BP to the Clean Air Act List of Hazardous Air Pollutants.  EPA Administrator Michael Regan signed the final rule on December 22, 2021 and this action was published in the Federal Register on January 5, 2022. The effective date of this final rule is February 4, 2022.
EMAP previously wrote about this topic which can be found here.
1-bromopropane (1-BP), also commonly known as nPB, is a chemical solvent often used in surface coating operations, dry cleaning, and in electronics and metal cleaning. 1-BP is also used an adhesive and is sometimes used in the manufacturing process in pharmaceutical and agricultural industries.

What does this rule mean for Pennsylvania small businesses?

If you are a Pennsylvania small business and use 1-BP as part of your operations, you will now need to take into account the use of 1-BP as a regulated Hazardous Air Pollutant (HAP). In Pennsylvania, an air quality permit is required if the actual emissions of a single HAP is greater than 1.0 ton per year or if emissions from multiple HAPs are greater than 2.5 tons per year. If you are an existing Pennsylvania small business that already uses 1-BP then you will now need to take into account the use of 1-BP in facility wide air quality permit limits, requirements, and reporting standards.

Are there any new special requirements that apply due to the 1-BP listing as a HAP?

Simply answered, no, there are no new requirements that will apply to a facility for simply using 1-BP in normal small business operations. The more complex narrative is that the use of 1-BP may affect a facility’s classification as an area source or air quality emissions into a major source, or Title V facility, due to the use of 1-BP and taking into account the facility’s Potential To Emit (PTE).  To help better explain this, EPA has put together a Question and Answers document on the Listing of 1-BP as a Clean Air Act Hazardous Air Pollutant.

Small Business Assistance with 1-BP

If any of this confuses you as a Pennsylvania small business owner or operator, EMAP’s highly skilled team of environmental assistance providers is available to talk one-on-one.  Simply call our toll-free environmental hotline at (877) ASK-EMAP or send us an email at questions@askemap.org.

Proposed Rulemaking for Dry Cleaning Facilities

EPA has proposed amendments to the National Perchloroethylene Air Emission Standards for Dry Cleaning Facilities. This proposal would add provisions which would require all dry-to-dry machines at new and existing facilities to have both refrigerated condensers and carbon adsorbers as secondary controls.
The request for comment period is currently open.  EPA seeks comments and information regarding the number of third generation and earlier model dry cleaning machines that potentially could still be in operation.  In addition, EPA seeks information on dry cleaning practices, processes, and control technologies that could reduce emissions from hazardous air pollutions, or HAPs, for fourth generation (or better) dry cleaning machines.
A copy of the rule summary, the new proposed rule, and fact sheets can be found here.
General speaking, most dry cleaning facilities and operations are small businesses.  Estimates from EPA report that there are approximately 10,000 to 15,000 perchloroethylene dry cleaning facilities in the United States.  Unfortunately, due to the COVID-19 pandemic it is estimated that 10-15% of perc dry cleaners have closed.
Jeremy Hancher is the EMAP Program Manager located at the Widener University SBDC.  He holds over 15 years of experience in environmental compliance, environmental policy, and program management.  He is proud to be the team lead of the award-winning EMAP program which provides free and confidential environmental assistance to the Pennsylvania small business community in fulfillment of the requirements of the Pennsylvania Air Pollution Control Act and Section 507 of the federal Clean Air Act.
In 2015, Jeremy was part of the team effort when EMAP was recognized by US EPA Administrator Gina McCarthy for Outstanding Accomplishments by a State Small Business Environmental Assistance Provider in Providing Technical Environmental Assistance to the Small Business Community. Jeremy holds a Bachelor’s degree from the University of Pittsburgh, a Master’s degree from the University of Pennsylvania, and a certificate from the Wharton School.