Vapor Intrusion Developments – New ASTM Standard
By: Gail Wurtzler
In March 2008, ASTM International issued its Standard E2600-08 entitled “Standard Practice for Assessment of Vapor Intrusion into Structures on Property Involved in Real Estate Transactions.” The purpose of the standard is to define “good commercial and customary practice” for real estate transactions in the United States for conducting vapor intrusion assessments for properties with, or in proximity to, contamination of soil and groundwater by certain volatile compounds. The goal is to identify whether there is a potential for a vapor intrusion condition to exist.
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Carbon Sequestration – An Update on EPA Rulemaking
and Other Issues and Developments
By: William Duffy and Steve Marlin
For years natural sources of carbon dioxide have been piped to oil reservoirs and utilized for enhanced oil recovery (EOR). More than 50 EOR projects in the Permian Basin of west Texas and eastern New Mexico and others in the Piceance Basin of northwest Colorado use CO2 flood technologies through injection wells regulated as Class II wells under the federal Underground Injection Controls (UIC) program implemented by U.S. EPA. In Colorado, the Colorado Oil and Gas Conservation Commission (COGCC) permits and regulates fluid injection wells for EOR. By all accounts, COGCC regulation of producers and the use of CO2 injection wells has successfully enhanced oil production while protecting underground sources of drinking water supplies, the goal of the federal Safe Drinking Water Act (SDWA) under which the UIC program operates. 42 U.S.C. §§ 300f – 300j26.
With increasing focus on the role of CO2 emissions in climate change, EPA announced plans to regulate carbon storage (as distinguished from EOR) under the UIC program. In contrast to use of CO2 as a product or agent for EOR, EPA views CO2 injection as an essential technology for control of greenhouse gases generated by coal-fired and natural gas power plants. Two public workshops have been held by EPA to date to collect information from stakeholder groups and the public to formulate a proposed rule, anticipated for release in July 2008, with a goal of issuing a final rule by 2010-2011. A third workshop is planned to follow issuance of EPA’s proposed rule in Fall 2008, and will focus on “long-term liability” issues related to “carbon capture and sequestration” (CCS).
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Air Permitting Source Aggregation in Colorado
By: John Jacus
The Colorado Department of Public Health and Environment, Air
Pollution Control Division (“APCD”), recently issued an addendum to a technical
review document in support of a renewal operating permit that it issued in
January of 2007 that will be of interest to EHS professionals in the oil and
gas industry.
That Addendum applies a recent EPA guidance
document, and clarifies how the State of Colorado will approach the issue of
“source aggregation” when permitting oil and gas production and gathering
facilities. This Addendum was prepared
in response to a Clean Air Act (“CAA”) petition filed by Rocky Mountain Clean Air
Action (“RMCAA”) which was granted by EPA Administrator Stephen L. Johnson
last February. In its decision to grant
the petition of RMCAA, EPA did not express any view as to whether source
aggregation would be required, as argued by RMCAA in its draft permit comments,
and later in its petition to EPA.
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