Seneca Resources’ Strategy for Regulatory and Voluntary Compliance

Seneca Resources Company, LLC, the exploration and production segment of National Fuel Gas Company, headquartered in Houston, Texas, explores, develops, and produces natural gas in the Appalachian Region, including the Marcellus and Utica Shales. Boasting a long history of environmental stewardship, innovation, and transparency, Seneca Resources aims to further reduce its already low methane intensity by continuing to develop and incorporate best-in-class operational and reporting procedures.

To learn more about how Seneca Resources prioritizes and integrates voluntary frameworks like MiQ, One Future, the EPA’s Methane Challenge, and The Environmental Partnership into everyday operations, we spoke with Teresa A. Buckingham, CSP, SMS, Manager, EHSQ & Sustainability at Seneca Resources Company. In her current role, Teresa is responsible for company safety, managing air quality, and assisting with sustainability initiatives that fall within the air quality, emissions, and climate elements.

Read as she shares exclusive insights on how the regulatory landscape in the U.S. has impacted daily operations at Seneca, and how they overcome challenges in reporting to ensure accuracy and efficiency on both the regulatory and voluntary front.

DOWNLOAD THE REPORT: Dissecting the U.S. Methane Regulation Landscape

Maryam Irfan, Industrial Decarbonization Network: How has the regulatory landscape in the U.S. impacted daily operations at Seneca, and how do you ensure compliance across multiple jurisdictions?

Teresa Buckingham: Over the last two years, we've seen a lot of regulatory changes and major rulemakings in the U.S. For instance, the EPA published the NSPS Quad Ob and c standards, which dictate performance standards and operational practices for oil and gas facilities. There is also the Subpart W rulemaking, which outlines how we now need to inventory, calculate, and report our emissions profile.

Additionally, we're expecting the Waste Emission Charge (WEC) rulemaking soon. So, as these rules were being proposed, we at Seneca, started to analyze the elements within each one and began strategizing and evaluating whether our facilities were already in compliance or if we needed to make changes.

We started by looking at improving our operations and equipment design for our well pad facilities to meet those upcoming standards. To do this effectively, we aimed to ensure clear and transparent communication with our operations teams regarding the content of the new rules, what the requirements would be, and how we should set up a strategy to ensure compliance at our facilities. Fortunately, we were already implementing various emissions reduction initiatives, such as replacing natural gas pneumatic devices and adopting best management practices for well liquid unloading.

Many of these initiatives positioned us well to comply with the new regulations as they came into effect. Ultimately, it was about staying proactive as the rules were proposed, developing a strategy to fit them into our normal operations, and then determining what changes were necessary to maintain compliance moving forward.

Maryam Irfan, Industrial Decarbonization Network: Can you share any solutions or technologies that have helped mitigate operational challenges related to regulatory compliance?

Teresa Buckingham: We have an incredible team of engineers, and our goal has been to create visibility and transparency with the operational groups. We present what needs to be accomplished in terms of compliance and offer them the flexibility to determine how we’ll meet those requirements.

For example, we’ve implemented solutions to track our emissions profile, allowing us to identify our major sources and monitor how they fluctuate throughout the reporting year. By providing this visibility to our operations group, we equip them with the tools and knowledge to focus on the areas that need attention. For instance, with our gas wells, as they age, well liquid unloading continues to be a challenge, but our team has done a fantastic job piloting solutions to mitigate emissions from these events and developing best management practices and operational procedures to handle them.

From the air quality group’s perspective, it’s about showing them where we’re seeing emissions, breaking down the data by location, and identifying areas with a high frequency of events. This knowledge empowers them to find the right solutions to address our emissions challenges.

Maryam Irfan, Industrial Decarbonization Network: Seneca Resources has achieved top-tier MiQ grading and joined key initiatives like One Future and The Environmental Partnership. How do you prioritize and integrate these voluntary commitments into operational decisions?

Teresa Buckingham: When we look at voluntary programs, we evaluate them to understand what value we can gain from becoming a member or signing on to a voluntary initiative. Additionally, we use these programs as guides for best practices in shaping our emission strategies, particularly in reducing methane emissions and setting our targets.

For example, with MIQ, we evaluated the program and found that while we were already implementing many of the required operational practices, we needed to improve our documentation and record-keeping. Additionally, we recognized that MiQ’s monitoring element would introduce aerial technologies as part of our strategy for detecting and reducing emissions. Since this is an evolving space, we piloted a few technologies and developed processes to respond to the results. Over the year, we worked with our teams to determine our approach and ensure we had a comprehensive emissions inventory to provide us with insights into what we’re missing and whether we have captured everything necessary to give us a clear picture of our company profile.

LISTEN: Episode 13: How Oil and Gas Companies Can Operationalize GHG Emissions Tracking

Maryam Irfan, Industrial Decarbonization Network: What were the major operational adjustments Seneca Resources had to implement to meet the high standards of MiQ grading and EPA’s Methane Challenge?

Teresa Buckingham: For MiQ grading and EPA’s Methane Challenge, we were already on track to meet many of the requirements of those programs. So, it was about ensuring a broad understanding of the standards, integrating them into our design and operational practices, and training our operational teams on the goals of those initiatives.

We found that the key area for improvement was documentation, so we focused on improving our records and gaining a better understanding of what is happening at our operational sites.

Maryam Irfan, Industrial Decarbonization Network: What are the biggest operational challenges in reporting for both regulatory and voluntary frameworks, and how does Seneca ensure the accuracy and efficiency of that reporting?

Teresa Buckingham: Whether it’s regulatory or voluntary, many of the programs require the same data with a few minor changes depending on the specific requirements. We have set up a standard for what gets reported in terms of operational records to allow us to calculate emissions and determine the necessary data. We base this on the strictest requirements because having more data helps us figure out where it fits in the reporting puzzle.

We have a lot of data, and each program wants it a little differently. It’s crucial to ensure that if we’re reporting to one agency, similar and accurate data is also being reported to other programs. We generally start with our regulatory reporting as our base, especially when we talk about our emissions profile, we use that as our starting point and then add on and layer additional data as necessary for the voluntary programs.

Maryam Irfan, Industrial Decarbonization Network: Looking forward, what do you consider the most pressing regulatory change that will challenge the industry’s current operational model, and how can operators prepare for that shift?

Teresa Buckingham: In general, we are seeing technology evolve very quickly. The last couple of years have felt like a whirlwind with different quantification technologies, and the visibility and measurement of methane emissions. For example, the Super Emitter Program was implemented under NSPS Quad OB in the U.S., and it will increase and offer more visibility on assets.

As an industry, we will need to understand what is happening at our locations in terms of operations, identify what is creating emissions, and find accurate ways to reduce and explain them due to the increased visibility.

Additionally, everyone is now talking about MMRV (Measurement, Monitoring, Reporting, Verification), which is a challenging element, especially when dealing with different quantification values from various technologies and the associated levels of uncertainty. We are still trying to figure out what all this means and how to connect the different pieces.

Maryam Irfan, Industrial Decarbonization Network: What are you most looking forward to at the Methane Mitigation America Summit?

Teresa Buckingham: I’m always looking forward to attending these events to share knowledge and get ideas from others. Here at Seneca, we have developed a good strategy for reducing emissions and meeting our targets, but I do believe there’s always something new to learn from others.

I’m interested to see what ideas others in the space are implementing, what’s working for them versus what’s not working, because we’re all trying similar approaches, but perhaps in slightly different ways.

DOWNLOAD THE REPORT: Dissecting the U.S. Methane Regulation Landscape

Learn more about maintaining operational efficiency and safeguarding corporate reputation amidst significant regulatory flux at our upcoming events: 

Methane Mitigation America Summit
December 3-5, 2024 | Houston, TX

Methane Mitigation Europe Summit
February 25-27, 2025 | Amsterdam, NL