NPRA suggests alternatives to EPA's proposed GHG regulations

Nick Snow
OGJ Washington Editor

WASHINGTON, DC, Dec. 29 -- The National Petrochemical & Refiners Association recommended three alternatives on Dec. 23 as it submitted comments to the US Environmental Protection Agency opposing EPA’s proposed greenhouse gas regulations under the Clean Air Act.

“The path to [GHG regulation under the CAA] that EPA has chosen is difficult, uncertain, and unnecessarily risky in these troubling economic times. The Tailoring Rule that is the subject of these comments is doomed to failure,” NPRA said.

“Fortunately, the timing, manner, and content of EPA’s overall approach to regulating GHGs under the CAA [are] firmly with the agency’s control,” NPRA said, adding, “Our comments outline ways in which EPA could proceed down alternative pathways that provide more sensible regulation without [resorting] to extraordinary administrative law principles that cannot be applied in these circumstances.”

EPA issued the proposed rulemaking, “Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule,” on Oct. 27. It would require facilities emitting more than 25,000 tons/year of GHGs to obtain permits demonstrating that they are using best practices and technologies to minimize GHG emissions, according to information at the agency’s web site.

It also proposes new GHG emissions thresholds defining when CAA permits under the New Source Review and Title V operating permits programs would be required for new or existing industrial plants. The proposed thresholds would “tailor” the requirement so it would not apply to small farms, restaurants, and other small businesses while covering refineries, power plants, and other large installations that EPA said are responsible for nearly 70% of the nation’s total GHG emissions from stationary sources.

Endangerment finding
The proposed rulemaking’s significance increased with EPA’s Dec. 7 announcement that it had determined that six GHGs pose significant dangers to human health and are potentially subject to CAA regulation.

NPRA recommended that EPA interpret that the CAA’s PSD provision be triggered only after a National Ambient Air Quality Standard is established for a pollutant. “Under this interpretation, which is fully consistent with the CAA and EPA’s regulations, the [Section] 202 Rule would result in GHGs only being subject to Best Available Control Technology requirements if a source otherwise triggers PSD for a criteria pollutant,” it said.

The agency also could delay issuing the 202 rule until it and the states are better prepared to address GHG permitting, NPRA continued. “EPA could use this time to pursue streamlining of PSD and Title V requirements on an aggressive time scale to avert the large economic impacts that the agency indicates Congress did not intend,” it said.

NPRA said EPA also could specify that under the 202 rule, the date when GHGs are considered subject to “actual control” would be when vehicle manufacturers must comply with an attribute-based standard for the 2012 model year. “This would avoid an imminent PSD trigger for stationary sources and give states and EPA more time to address GHG permitting issues,” the association said in its comments.

Contact Nick Snow at nicks@pennwell.com.

Related Articles

Inhofe, Lankford say new BIA rules threaten Osage oil operations

07/10/2015 New US Bureau of Indian Affairs regulations that increase production expenses on tribal lands could put the Osage Nation out of business, Oklahoma’...

House panel’s crude export ban hearing weighs urgency against caution

07/10/2015 A US House Energy and Commerce subcommittee hearing on legislation to repeal the ban on exporting US-produced crude oil quickly broke along party l...

Chevron Phillips Chemical makes executive appointments

07/10/2015

Chevron Phillips Chemical Co. LLC has made several executive appointments, all effective Aug. 1.

Twelve workers killed in Nigeria pipeline explosion

07/10/2015 Eni SPA reported that an explosion occurred July 9 at the repair site for the Tebidaba-Clough Creek oil pipeline in Nigeria’s onshore Niger Delta.

Gov. Tomblin forms West Virginia oil, gas safety commission

07/10/2015 West Virginia Gov. Earl Ray Tomblin (D) established the oil and gas safety commission he announced in his 2015 State of the State address. The grou...

MARKET WATCH: NYMEX, Brent crude oil prices rebound more than $1/bbl

07/10/2015 Prices for US light, sweet crude oil and Brent crude each rebounded by more than $1/bbl on their respective markets July 9, and analysts attributed...

Transco seeks FERC approval for New York Bay Expansion project

07/09/2015 Transcontinental Gas Pipe Line Co. LLC (Transco), a wholly owned subsidiary of Williams Partners LP, has filed an application with the US Federal E...

House Oversight panel subpoenas Kerry for Keystone XL documents

07/09/2015 The US House Oversight and Government Reform Committee issued a subpoena to US Sec. of State John F. Kerry for reports, recommendations, letters, a...

MARKET WATCH: NYMEX crude oil prices drop for fifth consecutive trading session

07/09/2015 US light, sweet crude oil prices settled slightly lower on the New York market July 8 for the fifth consecutive trading session, and analysts attri...
White Papers

2015 Global Engineering Information Management Solutions Competitive Strategy Innovation and Leadership Award

The Frost & Sullivan Best Practices Awards recognise companies in a variety of regional and global...
Sponsored by

Three Tips to Improve Safety in the Oil Field

Working oil fields will always be tough work with inherent risks. There’s no getting around that. Ther...
Sponsored by

Pipeline Integrity: Best Practices to Prevent, Detect, and Mitigate Commodity Releases

Commodity releases can have catastrophic consequences, so ensuring pipeline integrity is crucial for p...
Sponsored by

AVEVA’s Digital Asset Approach - Defining a new era of collaboration in capital projects and asset operations

There is constant, intensive change in the capital projects and asset life cycle management. New chall...
Sponsored by

Transforming the Oil and Gas Industry with EPPM

With budgets in the billions, timelines spanning years, and life cycles extending over decades, oil an...
Sponsored by

Asset Decommissioning in Oil & Gas: Transforming Business

Asset intensive organizations like Oil and Gas have their own industry specific challenges when it com...
Sponsored by

Squeezing the Green: How to Cut Petroleum Downstream Costs and Optimize Processing Efficiencies with Enterprise Project Portfolio Management Solutions

As the downstream petroleum industry grapples with change in every sector and at every level, includin...
Sponsored by

7 Steps to Improve Oil & Gas Asset Decommissioning

Global competition and volatile markets are creating a challenging business climate for project based ...
Sponsored by
Available Webcasts

On Demand

OGJ's Midyear Forecast 2015

Fri, Jul 10, 2015

This webcast is to be presented by OGJ Editor Bob Tippee and Senior Economic Editor Conglin Xu.  They will summarize the Midyear Forecast projections in key categories, note important changes from January’s forecasts, and examine reasons for the adjustments.

register:WEBCAST


Predictive Analytics in your digital oilfield - Optimize Production Yield and Reduce Operational Costs

Tue, Jul 7, 2015

Putting predictive analytics to work in your oilfield can help you anticipate failures, plan and schedule work in advance, eliminate emergency work and catastrophic failures, and at the same time you can optimize working capital and improve resource utilization.  When you apply analytic capabilities to critical production assets it is possible to reduce non-productive time and increase your yield.

Learn how IBM's analytics capabilities can be applied to critical production assets with the goal of reducing non-productive time, increasing yield and reducing operations costs.

register:WEBCAST


Cognitive Solutions for Upstream Oil and Gas

Fri, Jun 12, 2015

The oil & gas sector is under pressure on all sides. Reserves are limited and it’s becoming increasingly expensive to find and extract new resources. Margins are already being squeezed in an industry where one wrong decision can cost millions. Analyzing data used in energy exploration can save millions of dollars as we develop ways to predict where and how to extract the world’s massive energy reserves.

This session with IBM Subject Matter Experts will discuss how IBM Cognitive Solutions contribute to the oil and gas industry using predictive analytics and cognitive computing, as well as real time streaming for exploration and drilling.

register:WEBCAST


The Alternative Fuel Movement: Four Need-to-Know Excise Tax Complexities

Thu, Jun 4, 2015

Discussion on how to approach, and ultimately embrace, the alternative fuel market by pulling back the veil on excise tax complexities. Taxes may be an aggravating part of daily operations, but their accuracy is crucial in your path towards business success.

register:WEBCAST


Emerson Micro Motion Videos

Careers at TOTAL

Careers at TOTAL - Videos

More than 600 job openings are now online, watch videos and learn more!

 

Click Here to Watch

Other Oil & Gas Industry Jobs

Search More Job Listings >>
Stay Connected