Emissions Guidelines for Oil and Natural Gas Industry
On December 6, 2022, the Environmental Protection Agency (EPA) published “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review” (40 CFR 60, Subpart OOOOb and OOOOc, respectively). The purpose of this supplemental notice of proposed rulemaking is to modify the EPA’s prior proposal regarding updates to oil and gas industry emissions management requirements from November 15, 2021.
With this modification, the EPA added applicability for sources that were not previously addressed and refined the proposed conditions based on public comment regarding the 2021 requirements. Some notable updates include:
- Added applicability for dry seal centrifugal compressors (previously only wet seal centrifugal compressors were covered),intermittent bleed pneumatic controllers, and fugitives at compressor stations (pneumatic pumps and controllers at natural gas processing plants)
- Revised definition of “affected facility” and “modification” for pneumatic pumps and controllers
Operators with any of the equipment listed above should be aware of the potential applicability for new, reconstructed, and modified equipment subject to OOOOb, as well as the guidelines for existing equipment as outlined in OOOOc. Specifically for pneumatic equipment, operators must be ready to assess the applicability of combined site-wide equipment, as opposed to previous requirements that assessed applicability on a per-component basis.
Langan’s team of oil and gas engineering experts can help clients assess the impacts of this proposal on the operations of an individual facility or a company with multiple holdings for purposes of comment or purposes of anticipating future implementation impacts and costs.
Together these regulatory changes establish more aggressive emissions management rules for volatile organic compounds (VOCs) at oil and gas facilities developed or modified after November 15, 2021, and implement guidelines for VOC emissions at facilities that were previously not subject to OOOO/OOOOa requirements. The regulations also create performance standards and guidelines for methane capture and control at facilities, which had not previously been addressed. The White House estimates this finalized action will reduce methane from United States oil and gas operations by 87 percent below a 2005 baseline, in conjunction with prior proposals and current rules. To achieve these goals, this proposal:
- Increases the range of affected facilities subject to fugitive emissions monitoring and increases the frequency of inspections
- Includes measures to discourage abandonment of unplugged wells
- Limits the use of flares by requiring more waste gas to be captured or returned to use
- Adds applicability to previously unaddressed equipment
- Creates a “super-emitter” response program to quickly identify large releases for mitigation
While public comments have been requested for the entire proposal, the EPA is specifically seeking comments on the following items, selected for discussion based on potential implications on the reach of the final issued rule:
- Operating scenarios where a well liquids unloading event could be considered a “modification,” triggering a well affected facility. Specifically:
- The first time liquids unloading occurs
- The first time liquids unloading occurs after fracturing
- A change in the type of liquids unloading
- Ongoing liquids unloading as part of standard operations
- The feasibility and effectiveness of routing pneumatic controller emissions to process as a method of capture
- The potential for an “outermost retirement date”—affecting oil wells, storage vessels, pneumatic controllers, and pneumatic pumps—which would define a maximum age for a designated facility and allow for a less stringent standard based on remaining useful life
Operators (especially of older wells) should pay close attention to the outcome of the well liquids unloading line of public comment and if/how it could affect the OOOOb well affected facility applicability. Requiring older wells to be considered OOOOb well affected facilities based on liquids unloading status may require the implementation of costly practices to appropriately capture and control emissions from liquids unloading events.
This supplemental notice of rulemaking offers what could be the final opportunity for oil and gas operators to weigh in on potential environmental and economic impacts of what will likely become the final rule in the next round of legislative activity.
Erin Hansen is a Senior Project Manager specializing in air quality permitting and compliance, ESG, and carbon accounting. She has 10 years of consulting experience in oil and gas air program management and regulatory advisory.