Christopher J.,Trihydro Corporation
Society of Petroleum Engineers - SPE E and P Health, Safety, Security and Environmental Conference - Americas 2015 | Year: 2015
The U.S. Environmental Protection Agency (EPA) and several states have implemented, or propose to implement, new environmental regulations targeting air emission reductions from oil and gas facilities, including, for example, NSPS OOOO. As these programs mature, the industry is tasked with establishing increasingly complex compliance programs, including facilities that have not previously been subject to significant regulatory attention. While most operators have traditionally dealt with requirements established by the state oil and gas commissions, these regulations present a new type of concern for operators. Establishing systematic procedures and protocols can assist operators in meeting their compliance obligations in a consistent and defensible manner. The new air regulations often require testing or other observations, tracking data, and reporting obligations. Colorado's recently finalized Regulation 7 requirements often require the use of infrared cameras to observe hydrocarbon leakage from equipment, as well as audible, visual and olfactory (AVO) observations. While state regulations may not require procedures, training, or recordkeeping formats, it is in the operators' best interest to establish these steps to meet their internal requirements as well as establishing defensible data to demonstrate ongoing compliance. For example, if an infrared camera is used to detect hydrocarbon leaks, establishing a monitoring protocol ensures that the monitoring is conducted consistently, and that leak records will be tracked appropriately. A work practice procedure will establish responsibilities for tracking any discovered leaks, implementing maintenance requirements, and maintaining records to demonstrate compliance. When local operating personnel are responsible for compliance, establishing a training program and appropriate recordkeeping provisions will also help to ensure consistent program implementation. By establishing a systematic compliance effort, oil and gas operators can implement cost-effective strategies to meet these new compliance obligations. The optimal compliance approach will vary between operators based on internal resources and systems, and may require increasing staff resources or using external resources to meet these increasingly complex requirements. It is important for operators to consider these factors now to avoid unnecessary compliance hurdles down the road. Copyright 2015, Society of Petroleum Engineers.
Knauf M.,Trihydro Corporation
Environmental Conference 2013 | Year: 2013
In July of 2012, refineries, along with other manufacturers, were required to submit chemical production information under the Toxic Substance Control Act's (TSCA) Chemical Data Reporting Rule (CDR). The CDR is the most comprehensive set of information on chemical substances and their proposed uses available to EPA and the public. While supporting several facilities with the CDR, Trihydro Corporation (Trihydro) faced several challenges during the 2012 submission period related to regulatory changes from the previous submission year and general reporting complications. Resolving the issues led Trihydro to develop best practices and recommendations to reduce the CDR burden for future reports. Since the CDR required reporting is every four years, Trihydro also recommends several practices that facilities should be doing in the meantime. Many of Trihydro's recommendations are based on knowledge of the 2012 reporting period and the current regulation, TSCA reform is underway in Congress. While much of the reform is proposed, facilities should be aware of potential changes to the regulation.
McAlexander B.L.,Trihydro Corporation
Environmental Impact Assessment Review | Year: 2014
Petroleum-contaminated site management typically counts destruction of hydrocarbons by either natural or engineered processes as a beneficial component of remediation. While such oxidation of spilled hydrocarbons is often necessary for achieving risk reduction for nearby human and ecological receptors, site assessments tend to neglect that this also means that the pollutants are converted to greenhouse gases and emitted to the atmosphere. This article presents a suggestion that the current and long term greenhouse gas emissions from spilled hydrocarbons be incorporated to petroleum site assessments. This would provide a more complete picture of pollutant effects that could then be incorporated to remedial objectives. At some sites, this additional information may affect remedy selection. Possible examples include a shift in emphasis to remedial technologies that reduce pollutant greenhouse gas effects (e.g., by conversion of methane to carbon dioxide in the subsurface), and a more holistic context for considering remedial technologies with low emission footprints. © 2014 Elsevier Inc.
Wood-Black F.,Trihydro Corporation
NPRA Environmental Conference Papers | Year: 2010
The Toxic Substance Control Act (TSCA) is a regulation that typically does not get much notice in the refining industry except when the periodic inventory update rule (IUR) comes around. According to the EPA, the next reporting period is from 6/1/2010 to 9/30/2011, with the calendar year 2010 being the reporting year. Each IUR period requires facilities to evaluate their production in terms of quantity and process to ensure that the TSCA report is completed accurately. A discussion on the TSCA, with emphasis on preparing for the IUR covers potential reforms and reviews of TSCA; details required by the IUR; data gathering and process steps necessary to complete the IUR; lessons learned from EPA audits; and insights from the current regulatory discussions. This is an abstract of a paper presented at the 2010 Environmental Conference (San Antonio, TX 9/20-21/2010).
Wood-Black F.,Trihydro Corporation
Journal of Chemical Health and Safety | Year: 2011
The Toxic Substance Control Act (Act or TSCA) has been in place since 1976 with the primary, goal of reducing risks to the environment or to human health from chemical exposure by implementing, controls at the point of their manufacture, distribution, use, and/or disposal. This Act provides the, Environmental Protection Agency (EPA) with the authority to require reporting, record-keeping and, testing requirements, and restrictions relating to chemical substances and/or mixtures. This work, describes some important changes to the Inventory Update Rule to take effect in 2011. © 2010.