Valero Benefit for Children is Less Than Two Weeks Away

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If you’ve never heard of the Valero Texas Open Benefit for Children, TRICORD founder Joe Ibanez can sum it up in six words: “What they do has inspired me.” The 2018 Valero Benefit for Children will take place April 22-23 in San Antonio, Texas. It’s an event TRICORD participates in every year, and there’s a good reason why.

“They’re really walking the walk,” said Ibanez, who had Valero’s model of giving in mind during TRICORD’s founding. The Valero Texas Open golf tournament has become a leader in charitable fundraising since Valero became the title sponsor. Raising a record 11 million in 2017, the tournament has contributed more than $126 million to hundreds of charities, according to the official website.

Like Valero, TRICORD believes in the spirit of giving back.  In fact, one of TRICORD’s four leading principles is ‘Maintain a Spirit of Servant Leadership.’  This principle is not only documented in the SOQ, but ingrained in the TRICORD culture.

“When we lead through service, we focus on the growth and well-being of people and the communities to which they belong, rather than our own benefit,” says Ibanez. “Put into practice, this means we are committed to making the best decisions for our clients, even if it means less desirable work or a loss of profit for us.” It may seem counter business-intuitive, but it’s a good way to ensure that work is done with the client’s best interests at heart.

What’s more, in the image of Valero, TRICORD made a pledge of their own. Every year, TRICORD donates at least 10% of profits to customer programs that put others first, like the Valero Texas Open and Benefit for Children. Other causes that TRICORD regularly supports include the MS150 to raise awareness for muscular sclerosis and the Ronald McDonald House to support families with children in need of hospital care.

If you’re interested in attending the Texas Valero Open, it’s not too late. You can purchase tickets through Ticketmaster for the event here. Tickets are available as single-day or multiple-day passes. If you do attend, be sure to drop TRICORD a line – we’d love to meet up!

First Step in NSR Evaluations Now Allows Project Emissions Increases and Decreases

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By Kelly Bradberry

An EPA policy memo released March 13 changes past practices, now allowing permit applicants to include projected emissions decreases, as well as increases, during step one of determining whether a project is subject to New Source Review (NSR) permit requirements.

BACKGROUND

As a refresher, NSR dictates a procedure in determining whether a project triggers NSR permitting for an existing major source. The procedure’s first step requires that the project’s emissions increases aggregate be evaluated to determine if it meets the definition of a significant emissions increase. If a significant emissions increase is projected to occur, the procedure requires that a contemporaneous evaluation be completed on the project. The second step is a netting emissions analysis that takes into account any increases and decreases in emissions at the major source that are within the project‘s defined contemporaneous window.

WHAT CHANGED?

Under the new guidance, companies can now consider expected decreases in emissions resulting from the project during the first step, thus performing project emission accounting associated with only the project. As outlined in the memorandum by EPA Director, Scott Pruitt, “In contrast, “project emission accounting” more accurately captures what Step 1 of the NSR applicability process is really all about – i.e., taking account of the true emissions impacts of the project itself.”(1)

This memorandum removed an unnecessary obstacle for industry and paved the way for efficiency upgrades or installation of modern pollution control equipment in the future.


(1) Pruitt, Scott E. Environmental Protection Agency, (03/13/2018), Project Emissions Accounting Under the New Source Review Preconstruction Permitting Program.

You Can Read the Memo Here!

Be on the Lookout for a Revision to the Methane Waste Prevention Rule

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By Kelly Jean Bradberry

The Bureau of Land Management (BLM) will soon publish a proposal in the Federal Register to replace the “Waste Prevention, Production Subject to Royalties, and Resource Conservation” (82 FR 83008) rule, also referred to as the 2016 Final Rule.  Due to recent court rulings and several legal questions raised in pending litigation concerning the implementation of the 2016 Final Rule, the BLM is suspending the implementation of provisions of the rule that have not yet gone into effect.

Once the revised rule has been published, the 60-day public comment period will be kicked off.  After the 60-day period expires, the agency can make the revision final.  An update to this blog will be sent once the revision is published in the Federal Register (the expected release date is within the next few weeks).

Background 

The 2016 Final Rule was intended to reduce venting, flaring, and leaks of natural gas during oil and gas production activities on onshore Federal and Indian leases.  The final rule became effective on January 17, 2017, and while some requirements took effect immediately, the majority of the requirements were to be phased-in beginning January 17, 2018.  In short, the rule required oil and gas companies to capture methane flared at drilling sites; however, some companies consider the rule unnecessary and overly intrusive.

The current administration requested to have the rule set aside; however, a federal judge rejected the request citing that the administration had failed to provide a “reasoned explanation” for changing the rule and had not offered evidence as to why any of the past analyses of the rule were faulty.

Why Is this Effort Significant?

The revising of this rule is part of a larger effort to undo regulations that may have hindered economic growth in the energy sector in the past.  This regulation and other similar ones (perhaps other sectors of the economy rules) paves a path to striking a balance between protecting the environment and growing the economy.

Register for 2-Day LDAR Training in Austin, TX

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If you haven’t heard, TRICORD’s own Buzz Harris, Chris Lehmann, and David Ranum are hosting a 2-day LDAR Training Event April 3rd and 4th in Austin, Texas and you’re invited! In this blog post, you’ll find out what you can expect to learn and how to register for the event. And if there’s something you’re interested in that you don’t see on the agenda, please let us know!

Agenda

1.  Voice of the Customer – Tell us what you want to learn and your questions.

2.  Cover Applicable Regulations

How to Read Regulations

Historical and Current Regulatory Interpretations

3.  Principal Aspects of Method 21, OGI, and Component Identification (Revised in 2018)

4.  Monitoring Equipment

5.  Certification, Calibration, and Practical Use

6.  Audit-Proofing Your Database

7.  Program Management and Quality Assurance (Plant Level to Corporate)

8.  Regulatory Grey Areas and Interpretations (Revised in 2018)

9.  Emission Calculations (Revised in 2018)

Each day will start at 8:00 and run till 4:00. In addition to all the great learning you’ll do, the training is a great way to network and socialize with other LDAR professionals. A happy hour at the end of Day 1 will round out the day and make you fast friends with the affable Dave and Buzz. A lite breakfast and lunch buffets will also be provided each day.

To reserve your spot, simply fill out a registration form below and email it to david.ranum@tricordconsulting.com. And please let us know if there’s anything else you’d like to see on the agenda!

TRICORD 2018 LDAR TRAINING ELECTRONIC REGISTRATION FORM

“Once In, Always In” Rule the Latest Target of the New EPA

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Background

In May of 1995, the Environmental Protection Agency (EPA) issued a guidance memorandum to clarify the criteria for determining major Hazardous Air Pollutants (HAP) source status (greater than 10 tpy of any HAP or 25 tpy of any combination of HAPs) and whether a source may revert to area status (See “Potential to Emit for MACT Standards – Guidance on Timing Issues.” John Seitz, Director of Air Quality Planning and Standards, U.S. Environmental Protection Agency, May 16, 1995 (Seitz Memo)).  The memorandum defined the period in which a source could requalify as an area source via an enforceable limit on the source’s potential to emit and avoid being subject to major source requirements.  The Seitz Memo defined this as the period before, “a source must comply with an emission limitation or other substantive regulation requirement.”  In practical terms, the Seitz Memo established the policy that once the major source permit was issued and implemented by the source, the source would be classified as a major source regardless of any future enforceable limits.  The Seitz memo was referenced by the phrase “Once In, Always In” or the OIAI policy.

Overturning OIAI – New Policy Memorandum

On January 25, 2018, the EPA issued a guidance memorandum that overturns the OIAI policy (See “Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act.”  William L. Wehrum, Assistant Administrator, U.S. Environmental Protection Agency, (Wehrum Memo)).  The Wehrum Memo states the simple language of the Clean Air Act (CAA) in the definition of a major source should be interpreted literally, (i.e., a source should be classified on its permitted PTE).  Thus, the Wehrum memo allows a major source to take an enforceable limit to restrict emissions below major source thresholds and become reclassified as an area source not subject to major source requirements.

The Changing Face of EPA

This reversal in policy joins an expanding list of changes to EPA policies and rules over the past year.  The data below was published in the New York Times on December 15, 2017 (See Popovich, Nadja, Albeck-Ripka, Livia, Pierre-Louis, Kendra. “60 Environmental Rules on the Way Out Under Trump.” The New York Times 15 Dec. 2017: 1. Web. 26 Jan. 2018).  The article stated that twenty-nine EPA rules were overturned as of the posting date of the article.  High profile rules that were overturned include the following: Freeze On New Coal Leases On Public Lands; Methane Reporting Requirements; Decision On Keystone XL Pipeline; Decision On Dakota Access Pipeline; Clean Power Plan; Paris Climate Agreement; Emissions Standards For New, Modified And Reconstructed Power Plants; Regulations On Oil And Gas Drilling In Some National Parks; Drilling In The Arctic Wildlife Refuge; and Offshore Oil And Gas Leasing.  For the complete list and additional details, see the New York Times article referenced above.

Is the pendulum swinging towards an industry-friendly environment at the EPA?  Only time will tell.  Stay tuned for updates on this blog for additional changes in the policies and rules.