What is a SEP?
SEPs (Supplemental Environmental Projects) are voluntary projects that reduce pollution discharges or improve the quality of the environment. These projects are typically a part of a settlement agreement for an environmental enforcement action. Some state environmental regulatory agencies use the term Beneficial Environmental Projects (BEP) for their state only programs.
A respondent in an enforcement action (federal or state) may negotiate an agreement to perform a SEP in order to offset the assessed administrative penalty. You may pay the same amount of penalty, but can direct some of the funds to other projects that benefit the environment and maybe your company’s operations.
All proposed SEPs should have a direct and measurable environmental benefit. The SEP must be something that is not required by an existing permit, rule or regulation. They must be over and above what is required by regulation.
SEPs for state regulatory enforcement actions typically require the project to be conducted in that state. SEPs require there be adequate “nexus”. Nexus is the relationship between the violation and the proposed project. So for air quality enforcement actions, the SEP should be directed to reducing air pollution.
Commit to reduce flaring of vent gas at production facilities. If the facility air permit includes flaring, using a vapor recovery unit (VRU) to lower VOC emissions will be a perfect SEP to implement.
Use Low Bleed Pneumatic Devices
For oil and gas production facilities, NSPS OOOO requires the use of low bleed pneumatic devices for continuous bleed devices that use natural gas for devices installed after October 15, 2013.
For the SEP, retrofit existing pneumatic devices to use compressed air or replace them with low bleed devices for affected pneumatic devices installed on or before October 15, 2013.
Leak Detection and Repair (LDAR)
The EPA has identified fugitive leaks from valves, flanges, seals, tank thief hatches, etc. as significant sources of methane and VOC emissions. At this time, most oil and gas production facilities are not required to implement a formal leak detection and repair (LDAR) program.
Implement an LDAR program for the oil and gas production facility not required to by permit or regulation could be a good SEP that has an added value since it will increase profits and safety.
Well Venting from Unloading
The EPA has also identified natural gas venting from well unloading operations as a significant source of methane and VOC emissions. Use plunger lifts and recover this gas rather than venting the gas during the unloading operations. Use smart automation on wells to ensure the maximum amount of product goes to sales.
The above listed projects can be implemented now by oil and gas operators and do not require an uncomfortable and costly enforcement action to move forward.
The public and regulatory pressure to reduce methane and VOC emissions from oil and gas operations is a reality. Companies that use voluntary methods to reduce emissions may help slow the tide of ever increasing and more restrictive command and control regulations.
Let HY-BON help your company navigate a solution to managing vent gas.
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